Privacy

Project Information - Background

AquaSure Pty Ltd (ACN 135 956 393) (‘AquaSure’) has entered into a Project Deed with the Minister for Water of the State of Victoria and is contracted to finance, design, construct, operate and deliver desalinated water from the Victorian Desalination plant in Wonthaggi to the Victorian water system supply by 19 December 2011.

AquaSure contracted with Thiess Degremont Joint Venture (‘TDJV’) to design and construct, and with SUEZ Ventia Utility Services Joint Venture (‘Watersure’) to operate and maintain, the Project.

This policy is jointly provided by, and applies equally to, AquaSure, TDJV and Watersure. Accordingly, all references in this policy to AquaSure should be read as applying equally to AquaSure, TDJV and Watersure.

Purpose - Privacy Commitment

AquaSure recognises and respects the importance of each individual’s privacy.

AquaSure is committed to protecting the privacy of all individuals.

We will comply with the Privacy Act 1988 (Cth) (‘Act‘) and the Australian Privacy Principles (“APPs”) contained within that Act where we are required to do so. However, we are exempt from complying with the Act and the APPs to the extent that we are acting as a contracted service provider of the State of Victoria in connection with the Victorian Desalination Project. Accordingly, we have agreed with the State of Victoria to comply with the Information Privacy Principles (“IPP”) contained in the Privacy and Data Protection Act 2014(Vic) and the Health Privacy Principles contained in the Health Records Act 2001 (Vic) (collectively the "Victorian Privacy Laws") with respect to any act done, or practice engaged in by us for the purposes of the Victorian Desalination Project.

Scope

This document sets out our policy about how we manage and protect personal information, including your personal information. This policy ensures all personal information held by AquaSure is handled appropriately and kept confidential.

Distribution

All employees and officers of AquaSure are expected to comply with the Act, the Victorian Privacy Laws and this policy statement in handling personal information during and for the purposes of the Victorian Desalination Project.

Accordingly, AquaSure will:

• communicate this Privacy Policy to all employees and stakeholders to ensure awareness of the requirements to comply with privacy standards; and
• provide a copy of the Privacy Statement (as attached in Schedule 1) to any person who is asked to provide their personal information to AquaSure, and to any other person upon request.

Personal Information we hold about you

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

The personal information we hold about you may include your name, address, telephone/mobile number, email address, other contact details and your profession, occupation or job title, together with any additional personal information that you provide to us.

We do not collect information about your health or sensitive information about you (for example, information about your racial or ethnic origin or political opinion) unless we are authorised or required by law to do so or you have consented to us collecting that information from you for a particular purpose, in which case we will only use the information for that purpose.

How we collect your Personal Information

We collect only personal information that is necessary for the performance of AquaSure’s business in relation to the Victorian Desalination Project.

We collect your personal information from you unless it is unreasonable or impracticable to do so. We may collect personal information about you in a number of ways, including:

• directly from you - for example, when you provide information to us by phone, email, or through our website;
• if your image is captured as part of regular photography and videography carried out at the Victorian Desalination Project site;
• from third parties, such as our contractors and stakeholders and also from Victorian government departments and other government entities;
• from our own records when dealing with you; or
• when we are required by law to do so.

You may chose to remain anonymous whenever it is lawful and practical. If you chose not to provide the information we request, we may be unable to respond to your queries and will advise you so.

Our website

We may collect personal information about you when you access our websites. However, we do not collect personally identifying information about any person viewing AquaSure’s website except when knowingly provided by such individual.

When you visit our websites, our systems may record certain information about your use of our websites, such as which pages you visit, the time and date of your visit and the internet protocol (IP) address assigned to your computer. We do not use this information to identify you personally. Rather, we simply use this information to analyse and improve the performance of our websites.

In addition, we may use “cookies” on our websites. Cookies are small text files that help a website to track your web site usage and to remember your preferences. Using cookies is standard practice for most large websites. In some cases, the cookies we use may collect some personal information about you. We will treat this information in the same way as other personal information we collect about you.

We use Google Analytics to help analyse use of our website. This analytical tool uses “Cookies” to collect standard internet log information and visitor behaviour information. You can find out more about the way cookies work and Google Analytics on www.cookiecentral.com, www.allaboutcookies.org and www.google.com/analytics.

If you prefer, you may be able to disable cookies through your internet browser. However, if you do so, you may not be able to access certain areas of our websites or enjoy the improved website experience that cookies offer.

A Privacy Statement, as attached in Schedule 1, shall be published on the AquaSure website. Any person who provides their personal information to AquaSure shall be provided with the Privacy Statement or a note advising such person that they can access the Privacy Statement on the AquaSure website.

As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

How we use your personal information

We, and the organisations to which we may disclose your personal information under this policy (see below), may use your personal information for the primary purpose(s) of:

• verifying your identity;
• providing responses to your information queries and otherwise communicating with you in relation to the Victorian Desalination Project;
• administering and managing your application for employment or contractor positions or to notify you when new roles are released; and/or
• providing you with news and information relating to the Victorian Desalination Project.

We may also collect, hold, use and disclose personal information for the following purposes:

• to assess the performance of our website and to improve the operation of our website;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for the administrative, planning, development, quality control, research and stakeholder management purposes;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

Personal information of our employees and contractors is stored on our electronic systems, including in our payroll and accounting systems, and access is restricted to members of our finance team. Hardcopy records of payroll information and personnel files are also kept in a locked cabinet. Limited personal information about our employees and contractors may be held by their supervisor and/or available on AquaSure’s secure internal intranet.

How your personal information may be disclosed

We may disclose your personal information to other entities related to AquaSure and to our contractors, agents and stakeholders. Your personal information may be disclosed and shared between AquaSure, TDJV and Watersure. Except as permitted or required by law, we will only disclose your personal information to the extent necessary for the primary purposes set out above.

Personal information may be accessed by or disclosed to our employees or contractors that need to know that personal information (for example, to communicate with you).

Outside organisations we may disclose your personal information to include:

• your authorised representatives, including your legal advisers;
• our professional advisers, including our legal advisers;
• contractors we have engaged to provide services in relation to the Victorian Desalination Project;
• the State of Victoria’s Department of Energy, Environment and Climate Action as required under our agreement with the State of Victoria for the design, construction, operation and maintenance of the Victorian Desalination Project;
• our financiers; and
• other persons, including government and regulatory authorities, as required or authorised by law.

Personal information of our directors may be collected and disclosed to government authorities (such as to the Australian Securities and Investments Commission for the purposes of fulfilling our obligations under the Corporations Act 2001 (Cth) to keep our company records up to date) and to our financiers (for know your client purposes).

We store your personal information in Victoria and do not disclose your personal information outside of Victoria, except as described in this policy. If any of the above organisations are located outside Victoria we will ensure that these organisations abide by similar privacy principles and provide a similar level of privacy protection.

If we use or disclose an individual's personal information for a purpose (the “secondary purpose”) other than the main reason for which it was originally collected (the “primary purpose” as described above), to the extent required by the Act or the Victorian Privacy Laws (as applicable) we will ensure that:

• the secondary purpose is related to the primary purpose of collection and the individual would reasonably expect that we would use or disclose their information in that way; or
• the individual has consented to the use or disclosure of their personal information for the secondary purpose; or
• the use or disclosure is required or authorised by or under law; or
• the use or disclosure is otherwise permitted by the Act or the Victorian Privacy Laws (as applicable).

Keeping information accurate

We will take all reasonable steps to ensure that the personal information we record is accurate and complete at the time that it is recorded.

If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us (our contact details are below) and we will update our records.

Keeping information secure

We will take all reasonable steps to maintain the security of your personal information and to protect it from unauthorised access. We may hold your information in either electronic or hard copy form. We require technical security measures to be implemented on all mobile devices and we train our staff in security measures to minimise the risk of unauthorised access to the data that we hold.

The information you provide to us is only available to our authorised employees and contractors who need access to the information in order to perform their roles. We have a formal procedure in place for managing correspondence with landowners and other stakeholders. Telephone calls, website enquiries and emails to our general email addresses are also logged in our consultation management system.

Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later). We use a third party secure document destruction service provider to ensure that any physical documents that we are no longer required to maintain are securely destroyed.

How can you access or correct your personal information?

Subject to legal exceptions, we will provide individuals access to their personal information upon written request (see below our contact details). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we correct it. We will consider if the information requires correction. If we do not agree that there are grounds for correction then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Act or the Victorian Privacy Laws, if applicable).

Changes to our Privacy Policy

AquaSure may review and revise this Privacy Policy from time to time to maintain its relevance. Any updated versions of this privacy policy will be posted on our website and will be effective from the date of posting. You may find our up to date Privacy Policy at www.aquasure.com.au/privacy.

This privacy policy was last updated on 4 May 2020.

How to contact us

If you have any questions in relation to this Privacy Policy, would like a copy sent to you or have any other privacy-related queries, please contact:

Privacy Officer

AquaSure

Level 8, 80 Dorcas St Southbank VIC 3006

Tel: 1800 811 214

E-mail: privacy@aquasure.com.au. 

This email address should not be used for general enquiries. For such matters, please use contactus@aquasure.com.au

Useful links:

• The Victorian Commissioner for Privacy and Data Protection: www.ovic.vic.gov.au
• The Victorian Health Complaints Commissioner: www.hcc.vic.gov.au
• The Australian Information Commissioner: www.oaic.gov.au

 

Schedule 1 - Privacy Collection Statement

In accordance with AquaSure’s Privacy Policy, this Statement is to be published on AquaSure’s website and provided upon request to any person, including any person who provides their personal information to AquaSure Pty Ltd ACN 135 956 393 (“AquaSure’) in relation to the Victorian Desalination Project.

This Statement is jointly provided by, and applies equally to AquaSure, Thiess Degremont Joint Venture (TDJV) and Degremont Thiess Services Joint Venture (DTSJV). Accordingly, all references in this Statement to AquaSure should be read as applying equally to AquaSure, TDJV and DTSJV.

We collect, use, hold and disclose your personal information (which includes your name, address, telephone number, other contact details and any other personal information you provide to us) for the performance of AquaSure’s business in relation to the Victorian Desalination Project. This may involve disclosing your personal information to AquaSure and its employees, agents and contractors, the Victorian Government Department of Environment, Land, Water and Planning, our financiers as well as our contractors and service providers who assist us in designing, constructing, operating and maintaining the Victorian Desalination Project.

We will collect your personal information from you where possible, but we may also collect your information from third parties (in which case we will take reasonable steps to ensure that you are aware of the matters contained in this privacy collection statement). Your details and information about our contact with you will be held on our ‘Contact Database’. If you choose not to provide your personal information to us when we request, we may be unable to respond to your queries and we will advise you of this.

With regard to enquiries, your details will only be accessible and used by personnel dealing directly with your request. We do not use, or disclose, any personal details that you provide to us for the purposes of direct marketing.

However, you should be aware that the internet is not a secure environment. AquaSure uses all reasonable efforts to ensure that any personal information collected is held securely. In addition, only authorised personnel have access to personal information.

We will otherwise collect, hold, use and disclose your personal information in accordance with our Privacy Policy (a copy of which is available on our website at: www.aquasure.com.au/privacy), which sets out how you may access and correct the personal information that we hold about you and how to lodge a complaint relating to our treatment of your personal information.

Our contact details for privacy queries are:

Privacy Officer

AquaSure

Level 8, 80 Dorcas Street, Southbank VIC 3006

Tel: 1800 811 214

E- mail: privacy@aquasure.com.au

Any e-mails that you send will be automatically scanned, which could result in certain attachments and styles of message being automatically blocked and forwarded to our IT administrators in order to authorise the content. This is done purely for IT security purposes and our IT administrators will not access the contents of your e-mails once this process is completed.