Personal Data Privacy Notice
For the Operators in PTT Group
PTT Public Company Limited (hereinafter referred to as “PTT” or “we” or “our”) gives highest priority to the protection of your personal data, and in order for you to ensure that we will protect and manage your personal data in accordance with the laws concerning personal data protection, we then established this Personal Data Privacy Notice for your acknowledgement of details of the processing of personal data, whether it be the collection, use and disclosure (collectively referred to as “the processing”) that may be occurred and including to inform you of the rights on your personal data and our contact channels as follows:
1. Types of persons that we collect the personal data
Under this Personal Data Privacy Notice, PTT shall collect the personal data of the following persons: “Operator(s) in PTT Group” means the director, employee or other personnel of the companies that PTT holds shares and shall mean to include an employee of the companies that PTT holds shares which performs work at PTT pursuant to the policies or rules of PTT.
2. Purposes for the collection, use and disclosure of personal data
PTT shall collect, use and disclose your personal data by relying on relevant lawful basis for the following purposes:
| Clause | Purposes | Lawful Basis |
| 2.1 | For identity verification as an Operator in PTT Group. | Legitimate interest basis |
| 2.2 | For relevant contacting and coordination in relation to work collaboration between PTT and group companies including the notification of news and information concerning business operation or activities or projects between companies in PTT Group. | Legitimate interest basis |
| 2.3 | For the compliance with relevant policies of PTT and PTT Group and for using as information in support of the supervision of group companies, inspecting the operation and compliance with PTT Group way of conduct policy. | Legitimate interest basis |
| 2.4 | For coordination with external authorities in relation to the conduct of business in PTT Group. | Legitimate interest basis |
| 2.5 | For using in order to support the consideration and selection of employees to perform work in PTT, the consideration on the acceptance of employee transfer as PTT’s employee. In case that PTT has accepted an Operator in PTT Group, which is an employee of group companies, to perform work in PTT in accordance with the criteria specified in the internal regulations and rules of PTT, PTT may use your personal data for contacting and coordination, performing duties or conducting any transaction with Customers, Trade Partners, companies in PTT Group, government sectors, state enterprises, state authorities, public organizations, independent organization established under the laws, any other authority or third party, in the capacity of the representative of PTT, or performing work as assigned by PTT including the entering into agreements, the amendment to relevant contracts or agreements, the granting or obtaining of authority as well as providing clarification, information or statements to the third parties or participating in trainings, seminars, academic conferences or lectures for the third parties on behalf of PTT including for supporting the proceedings in accordance with internal procedures of PTT, performance evaluation or payment of remuneration for work or welfare. | Contractual and legitimate interest basis |
| 2.6 | For authority verification, granting or obtaining of authority including for using as supporting evidence for conducting relevant transactions. | Legitimate interest basis |
| 2.7 | For using as supplemented information of the meeting, joint operation, preparation of information before entering into joint procurement process between companies in PTT Group in accordance with the relevant internal rules, regulations and procedures of PTT in relation to procurement, preparation of relevant documents in relation to the operation, recording of the meeting and preparation of minutes of the meeting. | Legitimate interest basis |
| 2.8 | For public relations in relation to the proceedings of the project and meeting between PTT and group companies. | Legitimate interest basis |
| 2.9 | For using as supporting information for the checking of qualification or appropriateness on the performance of contracts or agreements that the companies in PTT Group have provided services for PTT. | Legitimate interest basis |
| 2.10 | For the provision of services under the contacts or agreements between PTT and group companies. | Legitimate interest basis |
| 2.11 | For work improvement or the provision of relevant services between PTT and companies in PTT Group. | Legitimate interest basis |
| 2.12 | For the collection and use of your personal data such as name-surname, position, work unit, picture, video and/or voice records in relation to the operations and activities of PTT for dissemination or public relations through relevant channels such as internal email of PTT and group companies, PTT’s website, Facebook, LINE, YouTube or other online media of PTT or other media such as television and publication, etc. | Legitimate interest basis |
| 2.13 | For using as information on the application for using electronic system or enabling the right to access or use internet or relevant electronic systems. | Legitimate interest basis |
| 2.14 | For the business planning, reporting and estimation, risk management, audit supervision including the internal audit of the internal audit office and internal management in the organization, including for the benefit of internal operations within PTT in relation to the disbursement of payment of the accounting and finance unit of PTT. | Legitimate interest basis |
| 2.15 | For the proceedings in relation to the assignment of any right, duty and benefit such as merger and acquisition, separation or business transfer which has duly been conducted in accordance with the laws. | Legitimate interest basis |
| 2.16 | For using as database of the stakeholders of PTT and/or using as an information for relationship management or relevant coordination in relation to PTT including opinion survey for analysis and improvement of PTT’s operation. | Legitimate interest basis |
| 2.17 | For the disclosure of information necessary for the compliance with relevant evaluation criteria participated by PTT. | Legitimate interest basis |
| 2.18 | For the investigation and inquiry of the complaint in the organization, corruption prevention or any other legal proceeding including the inspection and administration of complaints and allegations in relation to the operation of PTT or the related person for transparency and justification of all parties. | Legitimate interest basis |
| 2.19 | For accepting the application or consideration on the participation in relevant projects or activities of PTT such as field trip activity, Legitimate interest basis technical visit, site visit, receiving donation, seminar, training project or other projects of PTT or the projects that PTT proceeded in cooperation with the third parties or government authorities, etc. as well as the relevant proceedings in relation to the activity participation such as answering quiz for reward, the delivery of reward, the proceeding for management and administration concerning your heath, hygiene and safety such as the arrangement of health insurance for participating the field trip, etc. including for the evaluation, analysis and improvement of such projects or activities. | Legitimate interest basis |
| 2.20 | For maintaining security in building area, premises and gas stations of PTT including the exchange of cards for the entry and exit of such area, the recording of videos of the visitors of PTT or the buildings, premises and gas stations of PTT by closed-circuit television (CCTV). | Legitimate interest and legal obligation basis |
| 2.21 | For the establishment of legal claim, the granting or obtaining of authority, the compliance, exercise or defense of legal claim and relevant legal proceedings as well as the proceedings for legal execution. | Legitimate interest and legal obligation basis |
| 2.22 | For compliance with laws or compliance with court’s summon, letter or order of authorities, independent organizations or officers having duties and powers under the laws such as the compliance with a summon, writ of attachment, order of the court, police officers, public prosecutors and government authorities including the reporting or disclosure of information to the shareholders, government authorities or independent organizations such as Energy Regulatory Commission, Ministry of Energy, Revenue Department, Land Department, State Audit Office, the Office of National Anti-Corruption Commission, etc. for compliance with relevant laws. | Legal obligation basis |
| 2.23 | For the compliance with laws concerning public interest in respect of public health such as health protection against dangerous communicable disease or epidemic which may be contagious or spread into the kingdom. | Legal obligation basis |
| 2.24 | For the management and administration concerning your heath, hygiene and safety. | Preventing or suppressing danger to aperson's life, body or health (Vital Interests) |
In some cases, we may collect, use and disclose personal data of the person in the family or other person of reference that you provided for us. In this respect, PTT shall collect, use and disclose personal data of those people under relevant lawful basis for the following purposes:
| Clause | Purposes | Lawful Basis |
| 2.25 | In case that PTT has accepted an Operator in PTT Group, which is an employee of group companies, to perform work in PTT in accordance with the criteria specified in the internal regulations and rules of PTT, PTT may collect, use and disclose personal data of the family members of the Operator in PTT Group for the management of relevant welfare that PTT provides for family member of the Operator in PTT Group such medical treatment welfare, the provision of health insurance, etc. | Legitimate interests |
| 2.26 | For communication in necessary or emergency cases such as the notification of dangerous incident occurred to the Operator in PTT Group, etc. | Legitimate interests |
| 2.27 | For maintaining security in building area or premises of PTT and the evaluation of security risks including the communication for the issuance of access card(s) to work in the premises of PTT, the exchange of cards for building entry and exit, the requesting for car sticker, the recording of information on the entry and exit of PTT’s premises, and the recording of videos in the buildings or offices of PTT or PTT’s branches by closed-circuit television (CCTV). | Legitimate interests |
| 2.28 | For risk management and internal control in the organization, audit supervision including internal audit of the internal audit office, good governance and organization internal management. | Legitimate interests |
| 2.29 | For the establishment, compliance, exercise or defense of legal claim, using as supporting evidence of the legal proceeding, and relevant proceedings as well as the proceedings for legal execution. | Legitimate interests and legal obligation |
| 2.30 | For the compliance with the laws, the orders of the authorities, independent organization, or the competent officers such as the compliance with the summon, writ of attachment, orders of the court, the police officers, public prosecutors and government authorities, and the reporting or the disclosure of information to government authorities or independent authorities. | Legal obligation |
| 2.31 | For the management and administration concerning your heath, hygiene and safety. | Preventing or suppressing danger to a person's life, body or health (Vital Interests) |
In case that the personal data collected by PTT for the aforementioned purposes is the data necessary for the performance of agreements or the compliance with relevant applicable laws, if you refuse to provide such necessary personal data, PTT may not be able to consider entering into transaction or perform administration in accordance with the agreement with you (as the case may be).
Furthermore, in case that you have provided personal data of other person for us, you shall be responsible to inform those people of this Personal Data Privacy Notice and/or the letter requesting for consent (if necessary).
3 . Personal Data which shall be collected
In general, for the collection of your personal data, PTT shall collect your personal data by directly requesting the data from you; nonetheless, there may be some circumstances that PTT collects your personal data from other sources such as the company that you are positioned in, your employee, secretary or coordinator, government authorities, state authorities, insurance companies, medical centers or other sources of publicly disclosed information such as website and searchable data on the internet, etc.
In this regard, PTT shall proceed to collect your personal data as follows:
3.1 General personal data
(1) Identity data such as first name, last name, identification card number, passport number, date of birth, gender, age, nationality, signature, photo, identity number of the professional license, Employee ID (only for the case of an employee of companies in PTT Group), driving license, PTT’s defensive driving license, username, etc.;
(2) Contact data such as address, a copy of house registration, phone number, facsimile number, email, geolocation, emergency contact person, social media account, LINE ID, secretary information, etc.;
(3) Financial data such as bank account number, etc.;
(4) Communication data with PTT such as information concerning date, time and place having contact with PTT, information of the recording of video or voice upon having contact with PTT, etc.;
(5) Data regarding companies, authorities that you are working in or data in relation to the work operation such as companies or authorities that you are working in, place of work, position of work, level, length of experience in the rank, level, department or in PTT or PTT Group, year of retirement, records of annual performance evaluation result, records on position, competency assessment result, suitability evaluation result, competency analysis result, success profile evaluation and analysis result, personnel development method, etc.;
(6) Data regarding educational profile, work profile, training, proficiency and relevant achievements, etc.;
(7) Data regarding personal preferences and interest;
(8) Recording of videos by closed-circuit television (CCTV);
(9) Data on the participation of meetings between PTT and group companies including data on the participation of trainings, seminars, activities or other projects held by PTT as there may be the recording of photo, video or voice during such meetings, trainings, seminars or activities;
(10) Other necessary data for the legal proceeding or legal execution such as marriage status and data concerning assets, etc.;
(11) Opinions, recommendations and complaints;
(12) Records on the participation of relevant activities or projects with PTT;
(13) Screening data pursuant to communicable disease prevention measures;
(14) Driving behavior while using PTT’s car;
(15) Data concerning the utilization of relevant information systems of PTT including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.;
(16) Other personal data for the provision of facilitations as necessary such as the preferred food or beverage, etc.;
(17) Identity data of the person in the family (father, mother, spouse, adopted child, sibling with the same parent in common or with the father or the mother in common) such as first name, last name, identification card number, passport number, date of birth, place of birth, gender, age, signature, photo, nationality, etc.
3.2 Sensitive personal data
In general, PTT has no intention to collect and use religious and blood type data specified in your identification card for any specific purpose. In the event that you provided PTT the copy of your identification card, it is requested that you conceal such data. If you did not conceal such data, it shall be deemed that you authorized PTT to conceal those data and such document with concealed data shall be deemed valid and legally enforceable in all respects. In case that PTT is unable to conceal those data due to some technical limitation, PTT shall collect and use such data as a part of your identification documents only.
However, if it is necessary for PTT to collect sensitive personal data for any specific purpose that PTT could not rely on lawful basis for the Processing, PTT shall request for your prior express consent. In this regard, PTT may process the following sensitive personal data:
(1) Religious data;
(2) Data regarding health and/or disability;
(3) Biometric data;
(4) Racial data;
(5) Data regarding labour union membership;
4. Period for retention of personal data
PTT shall retain your personal data for the period necessary for the purposes of the collection, use or disclosure of personal data set out in this Privacy Notice. The criteria for determination of retention period are the period necessary for PTT to utilize your personal data in accordance with the purposes and it shall be further retained pursuant to the period necessary for the compliance with laws or the statutory prescription period, or for the establishment, compliance, exercise or defense of legal claim, or for other reasons pursuant to the internal policies and rules in the organization of PTT.
5. Disclosure of personal data
In order to carry out the proceedings for the purposes set out in this Privacy Notice, PTT may disclose your personal data to the third party as follows:
5.1 Companies in PTT Group;
5.2 The government authorities, regulatory authorities, state enterprises, state authorities, public organizations, independent organizations established under the laws or other authorities as prescribed by laws including the officers which exercise powers or perform duties under the laws such as court, polices, Revenue Department, the Office of Securities and Exchange Commission, Anti-Money Laundering Office, Department of Labour Skill Development, Welfare and Labour Protection Department, Energy Business Department, Ministry of Natural Resources and Environment, Ministry of Transport, Ministry of Energy, Office of the Ombudsman, State Audit Office of Thailand, House of Representatives Committee, House of Senate Committee, Department of Legal Execution, Office of the Attorney General, State Audit Office of Thailand, the Office of National Anti-Corruption Commission, National Science and Technology Development Agency, etc.;
5.3 Authorities, organizations, or the person relating to the exercise of right of claim, the commencing of legal proceeding, the objection to the complaint or the allegation, the defending of the case of PTT such as the parties of the case and witnesses, etc.;
5.4 Agents, contractors/sub-contractors and/or service providers for any operation provided for PTT such as professional advisors, transportation service providers, the service firms for the conducting of marketing activities, travel and accommodation agencies, the organizer companies for the convening of activities, trainings or seminars, activity organizers, media producers and advertising firms, insurers, auditors and legal advisors, etc.;
5.5 Persons Having Business Relationship (in case that it is necessary for the compliance with agreements in case that there is a joint operation of project or business);
5.6 Management system standards certification institutes;
5.7 Training participants;
5.8 Shareholders, debenture holders and the representatives of such persons;
5.9 Banks or financial institutions;
5.10 The transferee who received the assignment of any right, duty and benefit from PTT including the person assigned by such transferee to proceed on its behalf such as the case of the restructuring, merger and acquisition, separation or transfer of business, etc.;
5.11 Other third parties such as the disclosure of information in e-Government Procurement (e-GP) System, the announcement of relevant persons who have been selected through social media channels of PTT or the public relations of activity photos or news and information on the conducting of activities or projects of PTT to the mass media and third parties, etc.;
5.12 Hospital or clinic.
6. The submission or transfer of personal data to foreign countries
In some circumstance, we may be required to disclose your personal data to foreign countries, which may have standards of personal data protection different than those of Thailand because PTT has companies in the group which are located offshore. In addition, there are business operation or the conducting of relevant transactions with companies in foreign countries; therefore, we may be required to disclose your personal data to those companies including government authorities, professional advisors and the related persons having necessity to access to such personal data in the normal course of our business operation. Also, there might be the disclosure of information to foreign countries for supporting the commencement of legal proceedings or arbitrations which may be occurred in the future. Furthermore, PTT may store your data on computer server or in the cloud of offshore service providers and there might be the processing of data by using programs or applications of the offshore service providers.
In this regard, for the submission or transfer of your data to foreign countries in whatsoever case, PTT shall comply with the Personal Data Protection Act B.E 2562 (2019).
7. Your rights as the owner of personal data
As the owner of personal data, you have the rights as prescribed in the Personal Data Protection Act B.E 2562 (2019). In this respect, you can exercise your relevant rights through the channels specified by PTT in Clause 9 or through PTT Website (https://pttpdpa.pttplc.com/DataSubject), whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to PTT. The relevant rights having details as follows:
7.1 Right to withdraw consent
You shall have the right to withdraw the consent for the processing of your personal data that has already given to PTT unless such withdrawal of consent is restricted by laws or by the agreement that provides you the benefits.
Such withdrawal of consent shall not affect the processing of personal data legally conducted according to your prior consent.
7.2 Right to access to personal data
You have the right to request for an access to and the request for the copy of your personal data under control of PTT, including to request PTT to disclose the acquisition of such data that you have not given consent to PTT.
7.3 Right to request for the submission or the transfer of personal data
You have the right to request PTT to transfer your personal data that you have given to PTT as prescribed by laws.
7.4 Right to object the collection, use or disclosure of personal data
You have the right to object the processing of data relating to you in respect of the collection, use or disclosure of your personal data as prescribed by laws.
7.5 Right to request for the erasure of personal data
You have the right to request PTT to delete your personal data as prescribed by laws. Nevertheless, PTT may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, PTT shall destroy or cause such data to be unable to identify your identity.
7.6 Right to request the restriction of the use of personal data
You have the right to request PTT to restrict the use of your personal data as prescribed by laws. Nevertheless, PTT may store your personal data using electronic system pursuant to which some systems may be unable to delete the data, and for such case, PTT shall destroy or cause such data to be unable to identify your identity.
7.7 Right to request for the rectification of personal data
If you found that the data controlled by PTT is incorrect or you have changed your personal data, you have the right to request PTT to correct your personal data so that such personal data be accurate, current, complete and not causing misunderstanding.
7.8 Right to lodge a complaint
You have the right to lodge a complaint with the competent officers under the Personal Data Protection Act B.E 2562 (2019) in case that PTT breaches or does not comply with such Act.
8. Amendment of this Privacy Notice
We may amend and update this Privacy Notice from time to time, and if there is such amendment, we will keep you posted through PTT website (https://pttpdpa.pttplc.com) and/or inform you via email. If it is necessary to request for your consent, we will proceed to request additional consent from you.
9. Contact channels
If you have question or require further details concerning the protection of your personal data, the collection, use and disclose of your personal data, the exercising of your rights or if you have any complaint, you can contact PTT as per the following channels:
PTT Public Company Limited
Address: 555 Vibhavadi Rangsit Road, Chatuchak Sub-District, Chatuchak District, Bangkok 10900
Telephone: 02-537-2300
Data Protection Officer
Address: 555 Vibhavadi Rangsit Road, Chatuchak Sub-District, Chatuchak District, Bangkok 10900
Telephone: 02-537-2300
Email: pttdpo@pttplc.com
Announced on 18 August B.E. 2564 (2021)
Last Updated 19 Sep B.E. 2565 (2022)