Privacy

1. Collecting your Personal Information

1.1 What is personal information?

Personal information is information that identifies you as an individual or from which your identity can be reasonably identified.

The types of personal information we may collect include your name, address, email, telephone or fax number, date of birth, debit or credit card number and metering data (such as your meter location and electricity use). We may also collect other information of a personal nature that you disclose during communications with us, whether in person, over the telephone, via email or in writing. In addition, some personal information may be collected by CCTV cameras on our premises.

In some instances, we may also collect government identifiers, such as your driver’s licence or passport details, or a customer reference number if we are dealing with Centrelink on your behalf.

We may also collect information relating to your premise characteristics (such as number of occupants or staff, your premise income, duration of tenure at your address and mix of appliances), your views on your past, current and future electricity usage and any products or services that are under development.

1.2 What is credit information?

Credit information is personal information about your credit situation. We may collect credit information about you from credit reporting bodies (CRBs) to assess your credit worthiness and decide whether to provide you with our services on a post-paid account basis (e.g. where you receive our services now, but pay for them later).

The types of credit information we may collect include your identity particulars, details of other credit which has been provided to you, repayment details, more specific default information in certain circumstances, whether you have committed a serious credit infringement (e.g. acted fraudulently) and any court proceedings initiated against, or involving, you or personal insolvency information.

If we decide to open an account for you on a post-paid basis, we will then collect your credit information on an ongoing basis. This may include details about your repayments, any defaults on payments or changes to the terms and conditions of your account. We do this to form our own ongoing credit assessment about you.

1.3 What is the purpose for collecting personal information?

We only collect personal information that is reasonably necessary for our business functions and activities, including those that involve conducting research that may be of benefit to our customers, enable us to help our customers manage energy consumption and benefit electricity consumers in general, whether or not they are our customers and which enable us to respond to information requests from government.

For example, if you are a customer or potential customer, we collect your personal information for the purpose of providing high quality, safe and reliable power to you as the electricity generator, distributor and retailer for regional Western Australia. This may include using your personal information to decide whether to provide you with an account and then managing your account, applying concessions, billing and transactions.

We may also use your personal information to notify you of electricity outages, provide technical and maintenance information and services, conduct surveys and to help with any requests you may have. We may also collect your personal information for the purpose of conducting research into the behaviour and preferences of electricity consumers. This includes using your personal information for the purpose of developing products and services that are relevant to electricity consumers, as well as potentially informing public policy and regulatory discussion and decision making.

If you are a supplier or contractor, we collect your personal information for the purposes of engaging you to supply goods or services (or both) and then managing our ongoing relationship with you.

As a government trading entity, communications Horizon Power receives will be treated as a state record and will be retained as required by the State Records Act 2000 (WA) and other relevant regulations. We may also keep records of communications containing personal information (including recordings of emails and telephone calls) for the purpose of staff training. If we do not collect your personal information, we may not be able to do these things. For example, we may not be able to communicate with you and deal with your enquiries or applications.

1.4 How do we collect personal information?

There are several ways that we may collect your personal information. Additionally, Horizon Power holds your personal information in both physical and electronic forms in accordance with normal business practice.

The ways that we may collect your personal information are set out below:

1. 1. Directly from you

      If it is reasonable and practical to do so, we will collect your personal information directly from you. We may do this when we meet you in person, such as when you complete an application form, survey or contract or enter our premises. But we may also collect your personal information directly from you in other ways, including when we have a conversation with you over the telephone, you send an email or letter to us, you complete an online enquiry or survey, use Horizon Power's online or digital tools and applications or complete or commence an application form or you submit a tender.
      
      

   2. Indirectly

      If it is unreasonable or impracticable to collect your personal information directly from you, we may collect it from third parties. This may include collecting your personal information from third parties such as public sources, government agencies or your employer. If we are assessing whether to provide an account for you, we may collect credit information from CRBs. If we receive personal information about you from someone else without having asked for it, we will only continue to hold it if it is personal information that we could have collected from you ourselves, in accordance with this Privacy Policy.
      
      

   3. From our website or mobile applications

      If you are using our website or mobile applications, you will browse anonymously, except as set out in this section.
      
      For all visitors browsing our website, we use cookies to collect information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), the time of visit, pages visited and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also collect information about your location or activity while you use our website or mobile applications. We also use cookies to manage online advertising.
      
      Information collected in this way is not capable of personally identifying you.
      
      However, if you have provided us with personal information by completing an application form online or entering personal information in our mobile application, or if you use our online (and digital) tools and applications and we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our website, irrespective of how you access our site (e.g. from a third party website). We may also use that information to tailor your online experience.
      
      If you would prefer not to be identified in this way when using our website or would prefer us not to collect anonymous cookie information about you at all when using our website, you can delete the cookies and reconfigure the cookie preferences on your internet browser.

2. How we use and disclose your personal information

2.1 Using and disclosing personal information

We only hold, use and disclose personal information about you for the purposes outlined in section 1.3, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent.

For instance, we may collect, hold, use and disclose your personal information to process applications and payments, verify your identity and other details, manage our services (including monitoring, auditing and maintaining accurate records), manage our relationship with you, protect our lawful interests and deal with your enquiries and concerns. We may also collect, hold, use and disclose your personal information for the purpose of conducting or promoting research into the behaviour and preferences of electricity consumers. We may collect this information in order to inform product and service development and the development of public policy and regulatory discussion and decision making.

To do this, we may disclose your personal information to third parties who:

• • provide services which are necessary for us to conduct our business and research activities, such as providers of archival, data storage (including cloud based data storage providers), auditing, debt collection, banking, insurance, marketing, advertising, delivery, technology, data processing, research, investigation, professional advisory (legal, accounting, financial and business consulting) and security services;
  • are regulatory bodies (including in relation to our electricity licence conditions), government departments or government agencies (such as Centrelink), government ministers, law enforcement bodies, courts and dispute resolution schemes;
  • are account holders in respect of a premise that you occupy, if you are not the account holder;
  • are our partners in research, such as educational or public policy institutions and other parties (including the general public but only in an aggregated form that means you are not capable of being personally identified) that may have an interest in the implications or results of our research projects from the point of view of consumers, regulators, public policy decision makers or industry; or
  • are your authorised agents, executors, administrators or legal representatives.

We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity, and as part of a restructure or sale of Horizon Power.

We may hold personal information in, or disclose your personal information to, third party service providers who are located overseas. For example, if you use one of our mobile applications, the information we collect from your use of the mobile application may be held in a cloud based server overseas.

If:

• • we have your consent to the disclosure of your personal information to overseas recipients; or
  • we have taken reasonable steps to ensure that the third parties located overseas to whom we disclose your personal information are bound by; or
  • we are contractually required to uphold the standards of the Australian Privacy Principles,

we will comply with the Australian Privacy Principles when disclosing your information to that overseas recipient.

If:

• • you provide your consent to us disclosing your personal information to third parties in overseas locations, you agree that Australian Privacy Principle 8 (which requires us to take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles) does not apply; and
  • the third party handles your personal information in breach of the Australian Privacy Principles,

then Horizon Power will not be liable for the breach of the standards of the Australian Privacy Principles and you may not have redress against the third party for any breach by that third party.

As at the date this Privacy Policy was most recently updated, other than CCTV camera footage and any usage data Horizon Power obtains via your use of one of our mobile applications, Horizon Power will not hold personal information with, or disclose personal information to, any third party provider in an overseas location. If you use one of our mobile applications, usage data may be held by Google or Apple, which store information across multiple countries. CCTV camera footage may be held by cloud based data storage providers overseas across multiple countries.

2.2 Direct marketing

From time to time, we may use the personal information collected from you for direct marketing purposes, such as providing you with related energy news, promotions and special offers, targeted advertising and other information which we think you may find interesting.

We may contact you by telephone, electronic messages (e.g. email), online (including websites and mobile apps) and other means for these purposes.

If we do contact you in this way, it will only be in relation to matters that would reasonably be expected. And we will ensure that our marketing activities comply with applicable law.

If you no longer wish to receive any direct marketing communication from us, please follow the instructions for unsubscribing in our direct marketing communications. If there are no instructions, please contact us as set out in section 5 below.

2.3 Credit information

We may disclose your personal information to CRBs for purposes as described above in section 1.3. For example, if you fail to meet your payment obligations in relation to an account provided by us or if you commit a serious credit infringement, we may be entitled to disclose this to CRBs.

CRBs may include credit information provided by us in the reports given to other credit providers to assist them in assessing your credit worthiness.

We currently share credit information with the following CRB:

• • Corporate Scorecard: Suite 4, Level 7 100 Walker Street, North Sydney NSW 2059
  • Phone: (02) 9278 7925
  • Website: www.corporatescorecard.com.au

You are entitled under the Privacy Act 1988 (Cth) to request that a CRB not use or disclose credit reporting information they hold about you in circumstances where you reasonably believe that you have been, or are likely to be, a victim of fraud, including identity-related fraud. The period while this applies is called a “ban period”. You can make such a request to any of the CRBs listed above (which list may be amended from time to time).

3. Keeping personal information secure

Before disclosing personal information to a customer or contractor, we confirm the identity of that person to prevent misuse or unlawful disclosure of the information. We also take measures to ensure the physical security of personal information at Horizon Power. When records containing personal information are no longer required for our business or by law, we delete the information or permanently de-identify it. If you are considering sending us any personal information electronically, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard http).

4. Access and correction of personal information

4.1 Access

You may access the personal information we hold about you upon request.

You can make a request in an email or letter or by telephone. To make such a request, please see our contact details in section 5 below.

We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.

Your rights to access your personal information are subject to some limitations. We will not provide you with access to the extent it would be illegal to do so or, unless required otherwise by law, if it would have an unreasonable effect on the privacy of others or the request is frivolous or vexatious.

If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.

We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs.

4.2 Correction

We take reasonable steps to ensure that all personal information we hold is as accurate as possible.

If you feel that the personal information we hold for you is incorrect, you are able to contact us to request that we correct that information.

If you would like to do so please contact our Privacy Officer using the contact details in section 5 below.

We will normally try to resolve correction requests within 30 days of you making a request. If we need more time to resolve your request we will notify you in writing as to the delay and seek your agreement to a longer period. There will be no cost to you if we correct your personal information held by us.

5. Complaints

If you believe that we have not complied with our obligations relating to your personal information, please contact our Privacy Officer as follows:

• By phone: Call 1800 267 926 between 8am and 5pm Monday to Friday
• By mail: Privacy Officer PO Box 1066, Bentley DC, WA 6983
• By email: Send an email at any time to enquiries@horizonpower-reply.com.au

You will receive an acknowledgement of the receipt of your complaint as soon as practicable. If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or on 1300 363 992 or the Office of the Western Australian Information Commissioner at info@foi.wa.gov.au or on (08) 6551 7888.

6. Updates

We may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our current operations and practices.