Your privacy is important to Real Utilities.
This statement outlines the policy of Real Utilities Pty Limited and those of its related entities that are listed at frasersproperty.com.au/Real-Utilities/Home/Entities (together, called "Real Utilities”) on how we manage the personal information we hold (“Policy”). Set out at the end of this Policy, we include our credit reporting policy, which deals with particular types of personal information we handle in connection with the provision of credit to our customers..
It is Real Utilities' policy to respect the confidentiality of personal information and the privacy of individuals. Real Utilities is bound by the Privacy Act 1988 (Cth) (“Privacy Act”) including the Australian Privacy Principles (“Australian Privacy Principles”) and any relevant privacy code registered under the Privacy Act.
The Privacy Act defines 'personal information' as information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.
What kind of personal information do we collect?
The type of personal information we may collect and hold includes (but is not limited to) names, address, identification information, date of birth, age, contact details like phone numbers and email addresses, concession card details, payment card information, employment status, position held as well as other information contained in forms you provide. We also collect information about your interactions and communications with us (including in person, online and via telephone or email). Information is also collected regarding your use of the webpages under the URLs frasersproperty.com.au/Real-Utilities and realutilities.com.au (“Real Utilities Webpages”) (see further below).
Where an individual at premises to which we supply or may supply electricity has a requirement for life support equipment (“Life Support Customer”), we may collect and record these details, including details of any related health condition.
You must obtain the approval of any other person before providing us with their personal information to permit us to use such information for the purpose it was collected in accordance with this Policy.
The types of individuals we usually collect this information about include:
- customers, clients, applicants for electricity services and suppliers;
- individuals who share premises with the individuals described above, or who otherwise use electricity that we supply;
- job applicants, employees, and contractors;
- shareholders; and
- other people who may come into contact with Real Utilities in the ordinary course of our business.
What methods do we use to collect your personal information?
Personal information may be obtained directly from you, including by way of telephone conversations, emails, internet enquiries you make or forms you fill out (online or in hard copy), face-to-face meetings or interviews. There may be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect it directly from you. For example, we may obtain a reference from a third party. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
We may ask for other information voluntarily from time to time (for example, through market research or surveys) to enable us to improve our service or consider the wider needs of our customers or potential customers.
In most cases, if you do not provide information about yourself which Real Utilities has requested, Real Utilities may not be able to provide you with the relevant product or service.
Exception in relation to Employee Records: Real Utilities is not bound by the Australian Privacy Principles in relation to Real Utilities’ treatment of an employee record, if the treatment is directly related to the current or former employment relationship between Real Utilities and the employee. Employees of Real Utilities should contact their human resources representative for more information about how we handle employee information.
How do we use personal information and to whom may we disclose it?
Real Utilities uses personal information for the primary purpose for which it is collected. In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where you would reasonably expect us to and the purpose is related to the purpose of collection).
In general, Real Utilities collects personal information for the following purposes:
- to provide products or services that have been requested;
- to help us manage and enhance our products and services, including by analysing future customer needs;
- to facilitate our internal business processes;
- to communicate with you and respond to your complaints and enquiries;
- to assess the suitability of utility account applicants and customers;
- to prepare utility bills and process payments for customers;
- to provide ongoing marketing information about our products and services that we believe may be of interest to you (unless you opt out or we are prevented by law);
- to comply with legal obligations; and
- the recruitment of employees and contractors.
Depending on the product or service concerned, personal information may be disclosed to:
- related entities of Real Utilities;
- entities that are authorised under the energy laws (or that are otherwise exempt from this requirement) to provide electricity services to customers (“Electricity Service Providers”), on whose behalf we act as agent in providing electricity services;
- other parties involved in the electricity supply chain;
- trusted joint venture / alliance partners;
- service providers and specialist advisers to Real Utilities or Electricity Service Providers (as the case may be) who have been contracted to provide Real Utilities with services in relation to electricity supply arrangements (including metering related services) or administrative, technology, website hosting, financial, payment processing, research or other services;
- other insurers, courts, tribunals and regulatory authorities as agreed or authorised by law;
- reference agencies or insurance investigators; or
- anyone authorised by an individual, as specified by that individual or the contract.
Some of these organisations may be located overseas so they may not be subject to privacy obligations comparable to those under the Australian Privacy Act. We require that organisations outside the group comprising Real Utilities who handle or obtain personal information as service providers to Real Utilities acknowledge the confidentiality of this information and comply with the Australian Privacy Principles. We also generally require that these organisations only use this information for purposes authorised by us and that they otherwise follow our reasonable directions with respect to the handling and storage of this information.
Real Utilities may decide to buy or sell assets which form part of or relate to its business or a division or organisation within Real Utilities. In any such transaction, personal information will usually be one of the transferred assets and will be disclosed to the purchaser to use for the same purposes as it was previously used by Real Utilities.
Sensitive information is subject to greater restrictions
Some personal information which we collect is 'sensitive'. Sensitive information includes a person's racial or ethnic origin, religion, membership of political bodies or trade unions, sexual preferences or activities, criminal record, state of health and medical history. Sensitive information, specifically health information, may be relevant to applications by prospective employees and while consent will be sought before this is obtained, we may not be able to adequately assess candidates' suitability for some positions without this information. Real Utilities may act as an Electricity Service Provider or as an agent on behalf of Electricity Service Providers to provide electricity services to customers. In either of these capacities, Real Utilities is required to collect health information about customers receiving, or applicants for, electricity services from an Electricity Service Provider regarding Life Support Customers (whether the customer/applicant itself or a third party Life Support Customer). We will only collect, use and disclose health information or other sensitive information about a Life Support Customer with the consent of the relevant party, unless otherwise authorised by law. The Australian Privacy Principles require that sensitive information is used and disclosed only for the purposes for which it was provided, or for directly related secondary purposes, unless you agree otherwise or if the use or disclosure of this information is required by law (for example, to prevent a crime or serious injury).
Management and security of personal information
Real Utilities trains it employees who handle your information to comply with this Policy and the Privacy Act and to otherwise respect the confidentiality of your information and your privacy. Real Utilities regards breaches of your privacy very seriously.
How do we store personal information?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by telephone, mail, over the internet or other electronic media. We and our technology service providers hold personal information in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. The Privacy Act also requires us not to store personal information longer than necessary. Where we no longer require any personal information for a purpose permitted under the Privacy Act, we will take steps to destroy or de-identify it.
We will store your personal information in Australia for the purposes set out above. As mentioned above, Real Utilities may disclose your personal information overseas, including to New Zealand, China, Hong Kong, Canada, USA and other countries.
How do we keep personal information accurate and up-to-date?
We take reasonable steps to ensure that the personal information we hold about you is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible in order to update any personal information we hold about you. Our contact details are set out below.
You have the right to check what personal information about you we hold
Under the Privacy Act, you have the right to request access to any personal information which we hold about you and to advise us if the information should be corrected. The Privacy Act sets out the circumstances when we can refuse those requests. If we do refuse a request, we will provide you with a written notice that sets out the reasons (unless it would be unreasonable to provide them).
To make a request to access information we hold about you, please contact us in writing. We will require you to verify your identity and to specify what information you require. We may charge a fee to cover the cost of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
What if you have a complaint?
If you consider that any action of Real Utilities breaches this Policy, the Privacy Act, or a privacy code that applies to us, you can make a complaint through one of the contacts below. We will endeavour to act promptly in response to a complaint. If you are not satisfied with our response to your complaint, you can contact:
- Energy and Water Ombudsman of New South Wales, www.ewon.com.au, 1800 246 545
- the Australian Information Commissioner, www.oaic.gov.au, 1300 363 992.
How to contact us
You can contact us about a privacy-related issue by email, phone, facsimile or post:
Telephone: 1300 16 16 68
Mail: PO Box 621, Archerfield BC, QLD 4108
Updates to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
Review of this Policy
This Policy will be reviewed by Real Utilities every two years and at any other time considered appropriate by Real Utilities (such as if there is a change in privacy law).
Credit reporting policy
We are a credit provider in the sense that we offer electricity services to customers on a post-paid basis. This section applies to you if you are or you apply to be one of those customers. Except where specified otherwise, this section applies in addition to the other sections of this Policy.
We collect, hold, use and disclose particular types of personal information in connection with our credit provider activities. Some of this information relates to your applications and credit arrangements with us, and some of it relates to your applications and arrangements with other credit providers. We call this information ”personal credit information”, and it may include, to the extent permitted by law:
- identification details like name, date of birth, sex, current and former addresses, employer and driver's licence number;
- details of credit applications you have made including the amount and type of credit;
- details of your current and previous credit arrangements, including credit providers, start and end dates, credit limits and other terms and conditions;
- records of personal credit checks made about you with credit reporting bodies (“CRBs”);
- information about payment defaults, including details of agreed payment arrangements and subsequent repayment;
- a credit provider’s opinion that you have committed a serious credit infringement (eg, fraud);
- publicly available information relevant to your credit worthiness, including adverse court judgments and bankruptcy details;
- any credit score or credit risk assessment indicating a CRB’s, credit provider's or our analysis of an individual’s eligibility for consumer credit; and
- any other types of ‘credit information’ and ‘credit eligibility information’ about an individual permitted under the Privacy Act.
We may collect personal credit information as described in this Policy under ‘What methods do we use to collect your personal information?’. We also exchange personal credit information with CRBs. This helps them to maintain information about you to share with credit providers and other permitted parties for purposes including credit assessments.
Please note that you can request CRBs not to:
- use or disclose your personal credit information, if you are or are likely to be a victim of fraud; and
- use your personal credit information to determine your eligibility to receive direct marketing from credit providers.
We may also exchange personal credit information with your representatives, referees and legal advisors and with other credit providers, credit insurers, debt buyers and parties involved in any sale of our business or assets.
The purposes for which we may use and disclose your personal credit information collected from CRBs include:
- assessing your credit applications;
- rating your credit worthiness;
- managing your credit arrangements;
- collecting overdue payments;
- participating in the credit reporting system;
- assigning debts; and
- handling complaints and requests.
We may use and disclose other personal credit information for these purposes and also as described in this Policy under ‘How do we use personal information and to whom may we disclose it?’.
Please see the following sections of this Policy in relation to the storage of your personal credit information and your rights to access and correct that information, and make complaints:
- ‘How do we store personal information?’;
- ‘You have the right to check what personal information about you we hold’; and
- ‘What if you have a complaint?’
For some correction requests and complaints, we may need to consult with CRBs and other credit providers.