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Privacy policy

Principles

At SA Water, we are serious about protecting personal information and are committed to meeting community expectations and our obligations under the South Australian Government’s Information Privacy Principles and applicable laws.

Our integrity, transparency and accountability in managing and protecting personal information builds confidence with our people, customers and stakeholders.

By providing your personal information to us, you agree to us collecting, holding, using, disclosing, storing, handling and disposing of your personal information in accordance with this Policy.

Purpose

The purpose of this Policy is to outline the types of personal information we collect and how we collect, hold, use, disclose, store, handle and dispose of personal information. It also details how you can contact us about your personal information, including requests to access or correct your personal information.

Scope

This Policy applies to all personal information collected, held, used, disclosed, stored, handled and disposed of by SA Water Corporation and our employees, contractors and contracted service providers in the course of carrying out our business (together, SA Water, we, our or us).  It covers personal information in any form, for example, in hard copy, electronic or digital form and visual and audio recordings.

Collecting personal information

We will only collect personal information by lawful and fair means.  We will not collect personal information which is not reasonably necessary or relevant for our purposes, functions and activities.

How do we collect personal information?

We may collect personal information in a number of ways, including but not limited to the following.

We generally collect personal information directly from you, for example when you:

  • interact with us in person, by telephone or by correspondence (e.g. by letter, email or SMS) or provide information through our online portals or other digital platforms and services;
  • complete forms, applications or surveys, provide us with information or documents, or respond to our requests; or
  • subscribe to our services, newsletters or updates.

We also collect personal information from telephone recordings, or CCTV photographs or video surveillance at our sites [delete to the extent inapplicable].

In some circumstances, we may collect your personal information from other sources, for example:

  • from people you authorise us to contact, or from people acting on your behalf;
  • from a person acting under authority (such as a power of attorney);
  • where you have consented (e.g. referees);
  • from a recruiter where you are applying for employment with us; or
  • from other third parties, such as regulatory or public bodies, our suppliers, service providers or consultants, or publicly available databases and sources.

We collect information when you interact with our website, social media channels and other digital platforms and services, including through the use of Google Analytics, cookies and similar technologies.  For further information, please refer to our Cookies Statement. We do not use information collected in this manner to identify you personally, except in the unlikely event of an investigation into unauthorised or unlawful activity, to assist government and law enforcement agencies or regulators or otherwise as permitted or required by law or order of a court or tribunal.

Our website, social media channels and other digital platforms and services may from time to time contain links to other sites that are controlled by third parties.  You should consult the privacy policies for those other sites.  Please be aware that SA Water does not accept responsibility for any collection or use of personal information by those other sites.

If you provide us with personal information about another individual, you commit to us that you have first obtained lawful authority to do so or that individual’s consent to us collecting, using and handling that personal information in accordance with this Policy.

When we collect personal information, we will take such steps as are reasonable to make the person providing the information aware of:

  • the purpose for which the information is being collected;
  • whether the collection is authorised or required by or under law;
  • our usual practices with respect to disclosure of personal information collected; and
  • their right to access and, if necessary, request the correction of their personal information.

What types of personal information do we collect?

The types of personal information we collect will be dependent upon your interaction with us or the services we provide to you.  The types of personal information that we may collect and hold include, but are not limited to:

  • name, gender, date of birth, contact details (e.g. landline and mobile telephone numbers, email address), property and billing address, signature;
  • information contained in identity documents (e.g. driver’s licence or passport);
  • concession status and details;
  • property use, water use and waste information and plumber’s registration details;
  • credit card and/or bank account details;
  • company and trading name, Australian Business Number, Australian Company Number and GST registration (e.g. for corporate customers and suppliers);
  • occupation, education, qualification, employment, referee, citizenship, residency and visa details, and trade or professional memberships and associations (e.g. for employees and individuals applying for employment with SA Water);
  • tax file numbers, superannuation details, leave and payroll information (for employees of SA Water);
  • photographic images, video footage (including CCTV surveillance footage) and/or voice recordings;
  • online account and authentication information such as usernames, passwords, multi-factor authentication credentials, device identifiers, login history and security verification information;
  • information collected from our website, social media channels and other digital platforms and services (e.g. information about how you access, use and interact with our website and social media, the pages you have visited, and technical data such as IP address, device attributes, browser type, language and operating system);
  • information provided by regulators (such as the Energy and Water Ombudsman SA);
  • information from responses to requests for public consultation or engagement;
  • other kinds of personal information as permitted or required by law or by order of a court or tribunal; and
  • other personal information notified or requested at the time of collection.

In some circumstances, the personal information that we collect will include health or other sensitive information about an individual, where necessary for the functions and activities of our business (e.g. where relevant to services we provide to health-impaired individuals, or in connection with our employees or recruitment activities), or where the collection is required or authorised by law or order of a court or tribunal.

Where necessary for the services we provide, we also record information relating to deceased individuals, including name, date of death and identity of executor.

Storing personal information

We store most personal information in electronic storage systems and repositories operated by either us or our contracted service providers.  Some personal information may also be stored in physical form by us or our contracted service providers.

We take such steps as are reasonable to ensure that the personal information we hold or control is securely stored and protected from misuse, interference or loss and from unauthorised access, modification or disclosure.

We have in place procedures to deal with any suspected data breaches and in the event of a data breach, we will take relevant steps in accordance with applicable legal obligations.

We take reasonable steps to dispose of personal information in accordance with our legal obligations.

Using personal information

We use personal information for the purpose for which it was collected, including the following non-exhaustive reasons:

  • To provide our water, sewerage and recycled water services in accordance with the South Australian Water Corporation Act 1994 (SA) and Water Industry Act 2012 (SA), including to:
  • supply water through our network of water mains;
  • store, treat and supply bulk water;
  • remove and treat sewage through our sewerage systems;
  • supply recycled water through our network of recycled water mains;
  • manage our relationship with customers, manage customer accounts, respond to queries and validate a customer’s identity;
  • undertake appropriate billing and debt collection processes;
  • advise on the efficient and effective use of water;
  • To undertake our other functions under the South Australian Water Corporation Act 1994 (SA), including to:
  • carry out research and works to improve drinking water quality and sewage disposal and treatment methods;
  • provide consultancy and other services within areas of our expertise, such as laboratory testing services;
  • develop commercial and market products, processes and intellectual property produced or created in the course of our operations;
  • encourage and facilitate investment and participation, whether from within or outside South Australia, in the provision of water and sewerage services and facilities;
  • To undertake other statutory functions;
  • For research, coaching and training purposes, which help us understand our customers’ experiences of our services and how we can improve our services for all our customers;
  • To identify and tell individuals about services that may be of interest to them, conduct marketing and remarketing activities (including Facebook remarketing services), conduct competitions and provide promotional material;
  • To identify, manage, investigate, deter and minimise security risks, fraud, scams and other unauthorised activities, protect or defend our rights, interests or property, and protect the personal safety of our customers, employees or the public;
  • For our internal business processes, functions and activities and for insurance purposes;
  • To vet, validate or manage our relationships with suppliers, service providers or contractors;
  • To assess your qualifications and experience related to a job opportunity with us;
  • To manage and provide services to employees, including, for example, human resources and payroll services;
  • To meet obligations under the Freedom of Information Act 1991 (SA) or other State and Commonwealth legislation, comply with an order of a court or tribunal, and assist government and law enforcement agencies or regulators; and
  • Other purposes notified at the time of collection.

We do not use personal information for a purpose other than the purpose for which it was collected, or a purpose incidental to or connected with that purpose, except in the following circumstances as permitted by the Information Privacy Principles:

  • you would reasonably expect us to use the information for a secondary purpose, which is related to the primary purpose of collection;
  • you have expressly or impliedly consented to the use;
  • we believe, on reasonable grounds, that the use is necessary to prevent or lessen a serious threat to the life, health or safety of you or another person;
  • the use is required by or under law;
  • the use for that other purpose is reasonably necessary to enforce a criminal law or a law imposing a pecuniary penalty, to protect the public revenue, or to protect the interests of the government, a statutory authority or a statutory office-holder as an employer;
  • we have reason to suspect that unlawful activity has been, is being or may be engaged in, and disclosure of the personal information is a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities; or
  • we reasonably believe that the use relates to information about an individual that suggests that they have engaged or may engage in illegal conduct or serious misconduct in relation to a person, we reasonably believe that the use is appropriate in the circumstances, and the use complies with any Ministerial guidelines issued for the purposes of clause 4(10) of the Information Privacy Principles.

You have the right to refuse to provide us with your personal information. However, if you do not provide us with your personal information, we may not be able to provide you with some or all of our services, communicate with you, process or respond to your enquiry, application or request, or perform some of our statutory functions.

If we send you a survey, your response is voluntary.  If you don’t complete a survey, this will not impact any account you may have with us.

In some instances, you may deal with us on an anonymous basis or using a pseudonym (alias). For example, you can do this if you wish to discuss services we offer.  However, this may restrict or limit the services that we can provide to you.

If you are currently receiving any type of marketing or remarketing materials or similar communications from us and wish to be removed from one or more of these services, you may withdraw your consent to receive those materials or communications at any time by following the opt-out instructions provided in electronic communications from us or by contacting us at the details shown under “Contact us” below.

We may combine personal information held about an individual with other information we hold about that individual.

We do not sell personal information to third parties.

Disclosing personal information

We may transfer or disclose personal information to third parties in performing the purposes for which it was collected, such as to other property owners or tenants of a customer’s supply address, and to third parties who assist us in providing services or who perform services for us or on our behalf (for example, to our suppliers, contractors, consultants, advisors or providers of information technology, cloud storage, security, fraud prevention, payment or verification services or survey and research platforms).

We do not disclose personal information to a third party for a purpose that is not the purpose of collection, except in the following circumstances as permitted by the Information Privacy Principles:

  • you would reasonably expect us to disclose the information for a secondary purpose, which is related to the primary purpose of collection;
  • you have expressly or impliedly consented to the disclosure;
  • we believe, on reasonable grounds, that the disclosure is necessary to prevent or lessen a serious threat to the life, health or safety of you or another person;
  • the disclosure is required or authorised by or under law;
  • the disclosure is reasonably necessary to enforce a criminal law or a law imposing a pecuniary penalty, to protect public revenue, or to protect the interests of the government, a statutory authority or a statutory office-holder as an employer;
  • we have reason to suspect that unlawful activity has been, is being or may be engaged in, and disclosure of the personal information is a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities; or
  • we reasonably believe that the disclosure relates to information about an individual that suggests that they have engaged or may engage in illegal conduct or serious misconduct in relation to a person, we reasonably believe that the disclosure is appropriate in the circumstances, and the disclosure complies with any Ministerial guidelines issued for the purposes of clause 4(10) of the Information Privacy Principles.

Web traffic information is disclosed to Google Analytics when you visit our website. Google stores information across multiple countries.

When you communicate with us through a social network service, the social network provider and its partners, who may be located overseas, may collect and hold your personal information.

Accessing and correcting personal information

We provide access to an individual’s own personal information in accordance with the Freedom of Information Act 1991 (SA).

You also have rights under the Freedom of Information Act 1991 (SA) to request correction of your personal information.  We will correct personal information we hold or control in accordance with the Freedom of Information Act 1991 (SA) where we ascertain that the personal information:

  • is inaccurate;
  • is incomplete, irrelevant or out of date for the purpose of collection or an incidental or connected purpose; or
  • would give a misleading impression.

We will take reasonable steps to ensure that personal information held by us is accurate, complete and up-to-date.  If you become aware that personal information we hold is not accurate, complete or up-to-date, or if you have any other concerns or queries with regard to personal information held by us, please advise us as soon as practicable.

For information on how to apply under the Freedom of Information Act 1991 (SA) for access to or correction of your personal information, please call us on 1300 SA WATER (1300 729 283), log in to your account on mySAWater or contact our Privacy Officer at the details shown under “Contact Us” below.

Artificial intelligence

We use artificial intelligence products where they provide efficiencies and/or other advantages. Where we decide to use artificial intelligence products, we will comply with applicable laws and regulations.

Protecting your information from scams

We contact our customers through multiple channels. This includes electronic communications, such as email and SMS.  Please refer to the following if you become suspicious after receiving potential scam communications.

Scam emails, also known as phishing attacks, look like authentic emails from a service provider like SA Water.  They may ask you for payment or to update your contact details or in some cases, may ask for or provide you with seemingly unrelated information.

We will never email or SMS you to ask for your password, username, credit card or bank account details.  If you are unsure about a communication you have received that claims to be from SA Water, please call us on 1300 SA WATER (1300 729 283).

Be aware that scams can also occur via telephone.  People may pretend to be from a service provider like SA Water and try to gain access to your computer, bank account or money.  In this case, the best thing you can do is hang up and call us on 1300 SA WATER (1300 729 283).

Our contractors

Any personal information disclosed to a party contracted to SA Water will be considered disclosure to SA Water if disclosed to the party in their capacity as a contractor to SA Water.

Similarly, any collection, use or handling of personal information by a party contracted to SA Water will be considered collection, use or handling by SA Water if collected, used or handled by the party in their capacity as a contractor to SA Water.

Legislation

Certain legislation may override this Policy in full or in part and we will always be bound to comply with such legislation.

Questions or complaints

If you have any questions regarding this Policy or your personal information, or if you would like to raise a complaint about our compliance with this Policy or the Information Privacy Principles, please contact SA Water’s Privacy Officer (see details under “Contact us” below).

We will endeavour to respond to or address your question or complaint within a reasonable timeframe.

If you are not satisfied with our response, you can contact the Privacy Committee of South Australia (PrivacyCommittee@sa.gov.au).

Changes to this Policy

From time to time, we may update or change this Policy.  Any changes will be published on our website.

Definitions and Acronyms

TermDescription
CustomerAn individual, business or company who obtains a service from SA Water.
IndividualA natural person to whom personal information relates.
Information Privacy PrinciplesThe Information Privacy Principles set out in the Government of South Australia’s Premier and Cabinet Circular PC012 – Information Privacy Principles (IPPS) Instruction (as amended from time to time).
Personal informationAny information or opinion, whether true or not, relating to a natural person or the affairs of a natural person whose identity is apparent, or can reasonably be ascertained, from the information or opinion (or as otherwise defined in the Information Privacy Principles as amended from time to time).
Any reference to personal information in this Policy includes all personal information, regardless of whether it is obtained from individuals, business or corporate customers of SA Water, from third parties or other sources, or from and relating to SA Water employees.
PolicyThis Privacy Policy, as updated or amended from time to time.