Privacy Policy

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Privacy Policy

1. Introduction

Your privacy is important to us.

Sunwater Limited (ACN 131 034 985) and its subsidiaries (together, ‘us’, ‘we’, ‘our’) are committed to
protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act), including the
Australian Privacy Principles (APPs). We do this by ensuring that we comply with the Privacy Act,
including the APPs, in the collection, use, disclosure and storage of your Personal Information.

On this basis, the purpose of this policy is to explain how we deal with Personal Information in
connection with the operation of our business including how we collect and use Personal Information.

We may modify or update this policy from time to time by publishing it on our website. We encourage
you to check the Sunwater website periodically to ensure that you are aware of our current Privacy
Policy.

2. What is Personal Information?

Personal Information is defined under the Privacy Act to mean any information or 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 Privacy Act also recognises specific types of Personal Information in the form of ‘Sensitive
Information’ and affords this type of Personal Information with a higher level of protection under the
Privacy Act. Examples of Sensitive Personal Information includes information or an opinion about
someone’s:

racial or ethnic origin;

political opinions or associations;

religious or philosophical beliefs;

trade union membership or associations;

sexual orientation or practices;

criminal record;

health or genetic information; or
some aspects of biometric information.

3. What Personal Information does Sunwater collect?

We will only collect Personal Information that is reasonably necessary for one or more of our functions.
The types of Personal Information that we collect about you may include:

your name,
email address, address and other contact details (including phone number and company
information if relevant);
date of birth;
certificate of currency and ASIC company searches;
financial information such as banking details;
information regarding your water usage or account with Sunwater;
other information related to your dealings with us, which may include:
Personal Information in relation to a transfer of a water allocation (which may include collection
of government issued documents such as marriage and/or death certificates where relevant in
connection with a transfer of allocation);
Personal Information collected from contractors or third parties who provide services to Sunwater, for example Personal Information required in connection with background checks or qualification checks (which may include drivers licenses);
Sensitive Information in the form of video and audio recording as part of inspection activities or
health related information

We will also collect Personal Information in connection with specific circumstances, as set out in section
5.

If you do not want to provide us with certain Personal Information, or would like to deal with us
anonymously, you do not have to disclose Personal Information to us, but in these circumstances, we
may be unable to provide services, information or other arrangements to you (or the organisation you
work for) that are required from us.

Where we receive Personal Information about you that we did not specifically request and which we
could not have otherwise collected, we will, as soon as practicable, and where we are permitted by law
to do so, destroy the information or ensure it is de-identified.

4. How we collect Personal Information

Where reasonably possible, we will only collect Personal Information, including Sensitive Information,
directly from you or as otherwise authorised under the Privacy Act. We may collect your Personal
Information when you:

use or register for our website or online services, including when registering for Sunwater Online
or through the use of the Sunwater Customer App;
complete a form (including submitting a query via the ‘contact us’ page on our website) or a
survey;
engage with us via a third party website or social media channel; and/or
contact us (including in writing, electronically or via telephone) or otherwise directly engage with
us (for example, by visiting one of our facilities, submitting a Right to Information application,
engaging with our sponsorship opportunities, applying for a position at Sunwater, or entering a
competition run by us).

When you contact us by telephone, we may record the call for the purposes of quality assurance and
training. You will be informed that the call is being recorded and can request that the conversation not
be recorded if you would not like it recorded.

5. How we use and disclose Personal Information

We will only use or disclose your Personal Information:
a) in accordance with your written consent; or
b) for purposes connected with our business operations, which include (without limitation), the
following:

allowing visitors to our facilities;
notifying residents about relevant matters under Emergency Action Plans;
inspection activities, asset monitoring and for safety and security;
media use;
worker safety;
providing you with services related to your water allocation and usage (including transferring
water allocations);
identifying you to assist with the use of and subscription to our website services (including
Sunwater Online and the Sunwater Customer App);
processing your orders or applications;
dealing with requests, enquiries, requests for information or complaints and other customer
care related activities;
helping Sunwater to better understand your needs;
publishing available water allocations available for sale;
performing internal operations, including managing our contractors;
maintaining our records and internal reports, including the fulfilment of any legal requirements;
analysing our services and business needs with a view to developing new or improved services
and business practices;
ensuring safety and compliance with our reporting systems, including complying with all
legislative and regulatory requirements; and/or
as we are permitted or required by law.

We will not use or disclose your Personal Information collected for a particular purpose, for another
purpose without your consent unless:

you would reasonably expect us to use or disclose the information for another purpose, being a
purpose related, or directly related (where the information is Sensitive Information) to the
primary purpose;
the use or disclosure is required or authorised by law;
a permitted general situation exists in relation to the use or disclosure;
a permitted health situation exists in relation to the use or disclosure; and/or
the use or disclosure is reasonably necessary for one or more of the enforcement related
activities, on or on behalf of, an enforcement body.

We may disclose Personal Information about you to the following parties:

law enforcement agencies to assist in the prevention of criminal activities;
government agencies responsible for compliance matters or the investigation or resolution of
disputes or complaints concerning use of our services;
emergency services and other entities such as disaster management groups who provide
assistance during an emergency event;
our employees, suppliers, service providers, contractors, professional advisors, dealers, agents
and related companies for purposes that are related to providing you with a service that would
be reasonably expected;
anyone to whom our assets or business (or any part of it) is transferred or offered to be
transferred; and
as otherwise permitted or required by law.

We will not sell, rent or trade your Personal Information.

6. Collection and use of Personal Information in particular circumstances

In addition to the above, Sunwater may collect, use and disclose Personal Information in the following
specific circumstances.

Hardship
If you are experiencing hardship, we may collect additional information about your financial
circumstances. This information is collected from you, or from a third party (with your consent) in order
to assess your financial circumstances and determine how we can best assist you. In some circumstances
the Personal Information collected from you may include Sensitive Information, such as information
relating to your health and wellbeing. This will generally only be collected from you, where it is relevant
to assessing your financial circumstances and with your consent.

Additional Personal Information that we may collect to assist you with your hardship includes:

credit information;
employment status and income;
details of insurances held by you which are responsive to your hardship;
assets and liabilities;
photographs;
information relating to your health conditions and / or disability;
marriage and death certificates where relevant to your financial circumstances; and
information regarding your financial circumstances including financial statements, evidence that
you have requested assistances from the bank, and evidence of impact of hardship (this may
include a statutory declaration from you, about your financial circumstances).

Landowner and Occupier Information
We may collect Personal Information about you if you are a landowner or occupier located near our
infrastructure. This information, will be collected from you to enable us to contact you for the purpose of
our business (for example, to gain access to property) and where required in accordance with our
Emergency Action Plans. In very limited circumstances, where your consent has been obtained, this may
include the collection of your Personal or Sensitive Information via drone footage above or near your
property. You will be notified of any drone activity near your property, prior to such activity.

The Personal and/or Sensitive Information that collect may include:

Licence plate numbers; and
Images of you.

Procurement
We may collect Personal Information as part of our processes in procuring goods and services. In some
circumstances, we may collect Personal Information from third parties such credit reporting agencies,
where we are permitted by law to do so.

The Personal Information that we collect may include:

tax file numbers for vendor creation;
driver’s licence (for contractors who operate Sunwater vehicles); and
credit information (to assess the financial capacity to complete projects).

Information Relating to Employees, Contractors and Job Applicants
When you apply for a job or contract with us, we may collect certain Personal Information from third
parties, rather than directly from you (for example, we might collect Personal Information from a
recruitment consultant or from your previous employers). We will generally only collect your Personal
Information from third parties with your consent unless we are not reasonably able to do so.

The information that we collect may include Sensitive Information, such as your medical information
where this is related to a work-related injury or other work, health and safety matters, or is otherwise
relevant to your application. We will only collect this information with your consent, and directly from
you or from your medical practitioners, specialists, allied health professionals and/or rehabilitation
providers, unless we are otherwise permitted to do so in the circumstances outlined above.

The information that we collect may also include government related identifiers such as your tax file
number and ABN/ ACN (if required). These will be collected directly from you, either by us or from our
third party background check partner. We will only collect government related identifiers which are
reasonably necessary for your employment or engagement by Sunwater and will only use these
identifiers for the purpose of your employment or engagement with us or as otherwise authorised or
required by law. We will not adopt government related identifiers for internal use at Sunwater.

Personal Information (including Sensitive Information) that we collect in relation to employees,
contractors and job applicants includes:

your date and place of birth;
your reference and background check information (including verification of your identity, your
eligibility to work in Australia and if required, your driver’s license and/or passport/ visa details
and police checks and credit and bankruptcy checks);
bank details, superannuation details, financial information and credit information;
emergency contact information;
a description of your gender and sexual orientation;
whether you identify as an Aboriginal, Australian South Sea Islander or Torres Strait Islander
person;
whether you have a language other than English as your first language and / or used in your
home;
whether you are part of the Defence Force and / or a veteran;
psychometric test results (including identification of strengths) collected through the application
process;
information relating to any relevant medical condition including through pre-employment
medical checks;
whether you have a disability and if so details of that disability;
if you have been involved in a workplace accident, details of your workplace injury; and
your occupation and qualifications (including your education and/or work history and
professional memberships or qualifications);
government related identifiers;
documents which are necessary to identify you and / or assess your right to live and work in
Australia, such as your driver’s licence, passport, visa or Medicare number;
details of accreditations which are relevant to your employment or engagement with Sunwater,
such as your White Card qualification; and
medical information necessary to determine your fitness to complete the requirements of your
role.

This information may be used to assess your suitability for employment, or to be otherwise engaged by
us. With your consent, we may retain this information to assess your suitability for other roles at
Sunwater, which may also include notifying you about future roles that you may be suitable for. You may
request that we not use your Personal Information for this purpose. We will comply with any request
within a reasonable period after a request is made.

Certain information may be collected for the purpose of internal equality and diversity monitoring and /
or to assist Sunwater in making reasonable adjustments for employees as required. Provision of this
information is voluntary and will only be collected with your consent.

If you are seeking employment with us and do not want to disclose your Personal Information to us, or
want to deal with us anonymously, you may do this, however we may not be able to process your
application.

Information from Public Sources
Sunwater may collect information which is posted by you and which is publicly available, on its social
media channels for the purpose of the ongoing operation of its business.

7. Cookies and IP Address Tracking

We may collect information about you when you interact with our website. The information we may
collect includes your Internet Protocol address, browsing patterns, click stream data, HTTP protocol
elements, and the status of cookies.

Cookies are small amounts of information that are stored by your web browser. They are put on your
web browser by the websites that you visit. Cookies do not contain Personal Information, but they do
allow us to know if you visit the same website twice or if you visit related websites.
We send cookies when you:

view pages on our website;
send a request to Sunwater; or
register yourself on our website for certain services.

Most browsers automatically accept cookies by default, but you can refuse cookies or selectively adjust
your preferences in your browser. If you switch off cookies, certain features of our website may not be
available to you.

8. How we handle e-mail correspondence and feedback

We may disclose your Personal Information to recipients outside of Australia. Such recipients are likely to
be located in New Zealand, Canada, India, Singapore, the United Kingdom or the United States of
America. Before we disclose any Personal Information overseas (including through software and cloud-based solutions), we will take steps as are reasonable to ensure that the overseas recipient does not breach the APPs in relation to your Personal Information.

9. How we handle e-mail correspondence and feedback

As a Government Owned Corporation, email correspondences sent to us (including through forms on our
website) will be treated as a public record and will be retained as required by the Public Records Act
2023 (Qld) and any other relevant law.

Your name and address details will not be added to a mailing list, nor will we disclose these details to a
third party without your consent unless permitted to do so by law. However, email messages may be
monitored by our website support staff to assist with trouble shooting our systems and other
maintenance purposes.

10. Security

We are committed to protecting the Personal Information you provide to us. We store all Personal
Information collected by us in a secure environment. We take all reasonable steps to protect the
Personal Information that we hold from misuse, interference, loss, unauthorised access, modification or
disclosure. We have physical and electronic security systems, and we limit who can access your personal
information.

Where we no longer need your Personal Information, and we are not lawfully required to keep the
information, we will deal with your Personal Information in accordance with our policies and procedures
for the retention and disposal of Personal Information.

Please note, however, that the internet is not a secure environment and although care is taken,
we cannot guarantee the security of information provided to us via electronic means.

11. How you can access and correct your Personal Information

Under the Privacy Act you have a right to access, or request that we correct, the Personal Information
that we hold about you.

We take all reasonable steps to ensure that the Personal Information we collect, use or disclose is
accurate, complete, relevant, not misleading and up-to-date. To assist us, you should ensure that you
promptly advise us:

if there is any change to any of the details you have provided to us; or
if it comes to your attention that we possess certain information about you that is not correct,
accurate, complete, up-to-date or relevant, so that we can continue to provide you with the
services we have agreed to provide.

If you wish to access or update your Personal Information, including Personal Information which has
been disclosed to a third party, please contact our Privacy Contact Officer on the details set out below.
We may deny your request in certain circumstances, being the circumstances outlined in APP 12.3.

If we deny your request, we will tell you why.

If you ask us to provide you with access to Personal Information that we hold about you, we will provide
such information within a reasonable time. We will respond to a request for access within a reasonable
time of receiving your request. We may require proof of your identity before permitting access to or
changing records relating to you.

There is no charge for requesting access to, or correction of, Personal Information.
If we cannot provide you with access to your Personal Information or cannot make a requested
correction to the Personal Information, we will provide you with a written notice of our reasons for
refusal.

Please note that you may also make an application for access to or amendment of your Personal
Information under the Right to Information Act 2009 (Qld). See the Office of the Information
Commissioner website for further information: https://www.oic.qld.gov.au/

12. Complaints

If you wish to make a complaint about the way we have handled your Personal Information (including if
you think we have breached the Privacy Act) you may do so to our Privacy Contact Officer in writing, by
mail or email to the address or email address set out at the end of this policy.

When you contact us, please include your email address, name, address and telephone number and
clearly describe your complaint. Our Privacy Contact Officer will investigate the complaint and respond
to you promptly. If you consider that we have failed to resolve the complaint satisfactorily, you can make
a complaint to the Office of the Australian Information Commissioner, through their website:
https://www.oic.qld.gov.au/

Contact Details
If you have further queries or would like more information about our privacy and security
practices, please contact our Privacy Officer during our business hours of 9am to 5pm Monday
to Friday:

Privacy Officer
Sunwater Limited
Level 9, St Paul’s Terrace
Fortitude Valley Queensland 4006
PO Box 15536
City East Queensland 4002
Australia
Phone: +61 7 3120 0000
E-mail: IMPrivacyRequests@sunwater.com.au

13. Links to non-Sunwater websites

Please note that our website provides links to external websites. However, we do not control
these sites or the privacy practices of their operators. The privacy policies applicable to such sites may
differ substantially from this policy and we advise individuals to read those privacy policies before
using those websites.