Protecting your privacy
Goulburn-Murray Water is committed to protecting your privacy. This policy outlines our practices and policies for the collection, use and management of personal information.
In this policy 'personal information' refers to information or an opinion, recorded in any form, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
GMW is required to comply with the Privacy and Data Protection Act 2014 and is bound by the Information Privacy Principles set out in that Act. It may also be required to comply with other laws relating to the protection of personal information. For example, if GMW collects health information it is required to comply with the Health Privacy Principles set out in the Health Records Act 2001.
Why do we collect personal information?
To enable us to fulfil our responsibilities as a statutory water corporation we need to collect personal information about our customers, our employees, our contractors and service providers and their employees and about other individuals with whom we deal in the course of performing our functions.
Wherever possible we allow individuals to deal with us anonymously. For example, we can often answer general queries about our services without requiring you to identify yourself. However, the nature of our functions is such that we can usually only deal with identified individuals. In fact, there are some services which we can only provide to individuals who satisfy proof of identity requirements.
What personal information do we collect?
Usually we collect names, addresses and other contact details. What other information we collect generally depends on our relationship with an individual and the nature of the service we are providing.
For example, if you are an irrigation customer, we will usually need to collect information about your property and your water entitlements and/or usage, as well as banking details, proof of identity documentation and legal documents relating to ownership of land or water entitlements. If you are an employee or applicant for employment, we may need to collect information about your work history, work performance, qualifications and other relevant details.
What personal information are we legally required to collect?
We are required to collect a range of personal information under the Water Act 1989. This is mainly information about our customers who hold or are applying for water share transfers, delivery shares, take and use licences, water use licences or works licences. The information we require includes information about the customer (and sometimes other persons associated with the land or the entitlement) as well as information about the land, and about relevant water entitlements and usage.
This information may be required to be recorded on the Victorian Water Register. The Register is a public register which may be inspected by members of the public.
How do we collect personal information?
Most of the personal information we collect is provided in application forms and notices lodged by customers or their agents in connection with land disposition, water entitlements and licences, change of particulars and other transactions.
We also collect personal information in the course of in-person and telephone conversations, in correspondence and via our website. Personal information may also be collected through the use of surveillance devices installed at some of our offices and worksites.
Generally we try to collect personal information directly from the individual concerned. However there are circumstances where we need to collect personal information indirectly from third parties. This may happen for example when we engage contractors or consultants to communicate with or provide services to our customers.
For prospective contractors and employees, as well as customers, we may also need to collect personal information through employers, business associates, bankers, credit reference agencies and referees.
Health and other sensitive information
'Sensitive information' is personal information about an individual's racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, professional or trade association/union memberships, sexual preferences and practices or criminal record. In this policy, references to 'sensitive information' include 'health information'.
GMW generally does not collect sensitive information about its customers. However, some sensitive information may need to be collected where it may be of benefit to the customer, for example in considering a hardship application or other special circumstances relevant to services we provide to that customer.
We may collect sensitive information about our employees and contractors where necessary for purposes relating to employment or contractor selection or management.
We only collect sensitive information (including health information) with the individual's consent or where authorised under law. Sensitive information will only be used and disclosed for the primary purpose for which it was collected or a directly related secondary purpose.
What do we tell you about our collection of personal information?
When we collect personal information, whether we do so directly or indirectly, we are required to take reasonable steps to ensure individuals are aware of the information being collected, why we need to collect it, organisations or types of organisation to which the information may be disclosed, whether any law requires particular information to be collected, rights to access and correct the information and the main consequences, if any, of not providing it.
Usually we do this by a written notice in the form we use to collect the information. However, we may also inform people that we are collecting personal information through the media, through mail-outs or in notices provided when the information is collected.
What happens if information we require is not provided?
At all times we seek only to collect personal information to the extent that we need to do so to perform our functions. If you do not provide information we ask for, we may not be able to provide you with the services or assistance you require or expect.
Our use and disclosure of personal information
We use personal information we collect for a range of purposes connected with our functions as a statutory water corporation.
We use personal information about our customers for the purposes of administering water entitlements and licences, providing and managing irrigation infrastructure and performing other water-related services. These include infrastructure modernisation (through programs such as the Connections Program), promoting improved water management practices, educating the community about our functions and services and engaging with customers and other stakeholders in connection with our services and programs.
We use personal information about our employees and prospective employees and about contractors and suppliers for the purpose of providing services and performing our functions.
GMW does not use personal information for direct marketing purposes. However, we may compile mailing lists from customer information for the purposes of distributing information to our customers about our services and functions.
While we generally use your personal information for the primary purpose of collection, in some cases we may use or disclose it for a related secondary purpose that you would reasonably expect. We may also use or disclose your personal information with your consent.
We do not generally disclose personal information to persons or organisations outside GMW. However, we may need to do so where we use contractors or external service providers to undertake projects or provide services or where we work with other agencies to perform our functions or provide services to our customers. For example, if we engage contractors to carry out irrigation works, we may need to give them information about affected properties and their owners. When we undertake community education initiatives, we may need to provide personal information to our communications or mailing contractors. If we undertake a project with another agency that affects customers or stakeholders of both of GMW and the other agency, we may need to exchange personal information about those individuals.
We may also be required or authorised to disclose personal information by law or by court order. We are authorised under privacy law to disclose personal information for the purposes of protecting public revenue, investigating or preventing fraud or other unlawful or improper activity and for lessening or preventing a threat to public health or safety. Personal information relating to water usage and entitlements may also be disclosed where necessary for carrying out research in the public interest.
We may also make available to a person who applies under the Water Act 1989 information held on the Victorian Water Register for which GMW is responsible.
GMW generally does not disclose personal information to organisations outside Victoria. If it needs to do so, it will seek to ensure that the personal information is afforded the same level of privacy protection as it would receive if it were disclosed to an organisation in Victoria.
How do we protect personal information we hold?
GMW has put in place a number of procedural, physical, hardware and software safeguards to protect your personal information.
We use secure methods of communication and back-up systems to protect information from misuse, loss, unauthorised access, modification and disclosure.
Our information systems and files are kept secured from unauthorised access. We have procedures in place to ensure that our staff only have access to personal information in our databases to the extent that they need it in order to perform their job role.
Our staff and service providers have been informed of the importance we place on protecting your privacy and their role in helping us to do so. Our staff who handle personal information are required to undergo privacy training.
We require our contracted service providers to comply with privacy law and to ensure that any personal information we provide to them is protected. We require contractors and service providers who may be required to handle sensitive customer information to undergo privacy training.
How do we maintain the integrity of personal information?
In order to ensure that the personal information we hold is accurate and up to date, we have systems to ensure that when we receive new or updated information about an individual, all relevant records are updated. From time to time we review our data holdings to ensure the accuracy of personal data. This may involve data matching with personal information held by other agencies or Councils.
We are required to take reasonable steps to destroy personal information when it is no longer required. We do this by periodically reviewing and culling out-of-date files and databases (subject to any legal obligation to retain information and for archiving in compliance with the Public Records Act 1973).
What if you want to check what personal information we hold about you?
Subject to legal restrictions, you have a right to access and correct personal information we hold about you.
In most cases, requests for access will be administered in accordance with the Freedom of Information Act 1982. Under that Act we may refuse access on certain grounds, including where providing access may affect the privacy or the commercial or financial interests of others.
In addition to the standard application fee, if your request involves supply of documents, in accordance with the Act there will be a cost to you in order for us to provide this information.
If you believe there are errors in our records about you, please let us know and we will be happy to investigate and correct any inaccuracies.
Dealing with GMW on-line
Complaints and further information
If you believe that your privacy has been interfered with and wish to make a complaint, please complete the GMW Privacy Complaint Form and send to the Privacy Officer (see contact details below).
PO Box 165
TATURA VIC 3616
1800 013 357 (free call)
(03) 5826 3500 (standard call)