Privacy
Policy
1
ABOUT THIS POLICY
1.1. This is the Privacy
Policy of Alinta Energy Pty Limited (ABN 64 614 975 629) and the Oven Mountain
Pumped Hydro Storage Project (the Project).
1.2. Protecting your
privacy is crucial to the way Alinta Energy conducts our business. This Privacy
Policy describes how we carefully manage and safeguard your Personal
Information (including sensitive information), how we collect and use all of
this information to provide our products and services to you and how we comply
with our obligations under the Privacy Act 1988 (Cth) (Privacy
Act).
1.3. We take privacy
seriously at Alinta Energy and we are committed to protecting your privacy —
not just because it is the law, but because handling Personal Information
transparently and responsibly is a key part of creating a great stakeholder,
employee and business partner experience. Alinta Energy does not sell, rent or
trade your Personal Information.
1.4. The Privacy Act
defines Personal Information as:
Information or an opinion about an identified
individual, or an individual who is reasonably identifiable:
a. whether the information or opinion
is true or not; and
b. whether the information or opinion
is recorded in a material form or not.
Why Alinta Energy’s Privacy
Policy is important
1.5. Alinta Energy
collects, holds, uses and discloses Personal Information to carry out Project
functions or activities and to comply with our obligations under the Privacy
Act and the Australian Privacy Principles (APPs).
1.6. This Privacy Policy
guides Alinta Energy and regulates how we manage and protect your Personal
Information.
Who is responsible for your
Personal Information?
1.7. Alinta Energy is
responsible for the safekeeping of Personal Information that is provided to us.
2 TYPES OF PERSONAL
INFORMATION WE COLLECT
If you are a stakeholder of
the Project, we may collect information about you in order to keep you updated
about the Project and manage our communication with you.
2.1. The main way Alinta
Energy collects Personal Information about you is when you provide it to us.
2.2. The information Alinta
Energy collects may include:
·
your contact information,
such as your name, address, email address, telephone number, mobile phone
number, properties you own, the organisation you work for or are associated
with and your role
·
information you provide to
us in correspondence such as letters and emails, notes we take after phone
calls with you, and notes we take after meetings or other face-to-face
discussions with you.
3. HOW WE COLLECT PERSONAL
INFORMATION
Directly from you
3.1. In many instances,
Alinta Energy collects Personal Information directly from you. For example, if
you are a stakeholder, we may collect your information during a meeting, when
you contact us by phone, email, through our website or via social media sites.
3.2. Some other examples of
how Alinta Energy collects Personal Information include:
·
If you register for email
updates via our website
·
If you engage with us via social
media, phone, email or in person
·
When you or your
organisation offer to provide, or provide, products and or services to us.
·
When you participate in an
engagement activity or consultation.
Through other means
3.3. In the course of the Project’s
development and planning, we may collect Personal Information about you indirectly
from publicly available sources or from third parties such as:
·
through land title searches
to determine land ownership
·
from websites such as local
Councillor or community group information.
Alinta Energy will only
store this information for as long as it is needed to perform the function or
activity for which it was collected. Alinta Energy will destroy or de-identify
information when it is no longer required for that purpose.
3.4. Alinta Energy may
collect Personal Information via our website - see Part 5 Using our
Website and Cookies below.
3.5. Alinta Energy may also
collect Personal Information that you provide to us when signing up to mailing
lists and registering for our events.
Anonymity
3.6. Whenever it is lawful
and practicable, Alinta Energy will allow you to interact with us anonymously
or by using a pseudonym.
3.7. However, for some of
our Project functions and activities Alinta Energy usually requires your name,
contact information and enough information about the particular matter to
enable us to fairly and efficiently handle your inquiry, request, complaint or
application, or to respond to you, the relevant authorities or to another
effected individual/organisations.
4. WHY WE COLLECT, USE AND
DISCLOSE PERSONAL INFORMATION
4.1. Alinta Energy
collects, holds, uses and shares your Personal Information for our Project
functions and activities, which includes managing the Project and complying
with the law. We handle your information so we can:
·
confirm and/or validate
your identity
·
communicate with you and to
keep you updated regarding Project activities
·
respond to your enquiries
and resolve complaints
·
comply with our regulatory
obligations, report to regulators and authorities and assess our legal
compliance (including through internal and external audits).
4.2. If Alinta Energy does
not have your Personal Information, we may not be able to respond to your
questions or comply with the law.
Who we disclose Personal
Information to?
4.3. Alinta Energy may disclose
your Personal Information for the purposes described in this Policy to:
·
our employees, consultants
and sub-contractors responsible for stakeholder engagement
·
Regulatory bodies and Law
Enforcement Agencies (e.g., the NSW Environmental Protection Authority, the
Office of the Australian Information Commissioner, the NSW Ombudsman, and the
Police)
·
other persons as required
or permitted by law.
4.4. Alinta Energy takes
reasonable measures to ensure that the parties we share your information with
are bound by confidentiality and the Privacy Act.
What we will not do with
your Personal Information
4.5. Alinta Energy will not
use or disclose your Personal Information for another purpose (a secondary
purpose) unless:
·
we first obtain your
consent
·
you would reasonably expect
us to use or disclose your Personal Information for a secondary purpose that is
related to the primary purpose
·
it is set out in this
Policy
·
we are required to by Law
·
a permitted general purpose
exists
·
we believe it is reasonably
necessary for one or more enforcement related activities conducted by, or on
behalf of, an enforcement body.
4.6. If Alinta Energy
collects Sensitive Information about you, you consent to us collecting, using
and disclosing the Sensitive Information for the purpose for which it was
collected as disclosed and as permitted by the Privacy Act or other relevant
legislation.
Direct marketing
4.7. Alinta Energy and/or
our consultants and sub-contractors may send you direct communications and
information about the Project. This may take the form of emails, SMS, mail or
other forms of communication.
4.8. These communications
may also be sent to you even if you are not, or no longer, a Project
stakeholder.
4.9. You may opt-out of
receiving these communications by clicking on the unsubscribe link in the
electronic communication or by contacting us on 1800 518 194.
5 USING OUR WEBSITE AND
COOKIES
5.1. The Project’s website,
www.ompshydro.com, is hosted in Australia and there are two ways in which we
collect information through our website.
5.2. Alinta Energy may
collect Personal Information about you when you submit an online enquiry or sign
up to our mailing list.
5.3. The Project’s website
includes pages that use cookies which are small amounts of data sent by our
website and other third parties and stored on your computer’s hard drive. This
allows our servers to recognise your computer when you visit our website in the
future. Although cookies are used to collect data about your browser type, the
operating system you are using, the web page you visited, your internet service
provider and your State location, Alinta Energy does not use this data to
identify you personally.
5.5. You can configure your
internet browser to accept all cookies, reject all cookies or notify you when a
cookie is sent. If you refuse the use of cookies in this way you may not be
able to access the full functionality of Alinta Energy’s website. Please refer
to your internet browser’s instructions or help screens to learn more about
these functions.
5.6. To assess the
effectiveness of Alinta Energy’s website design and layout, as well as monitor
traffic to the website, we may contract with third parties to collect
statistical data. However no Personal Information is collected during this
process.
5.7. The Project’s website
may contain links to websites operated by third parties. Those links are
provided for convenience and may not remain current or be maintained. Unless
expressly stated otherwise, Alinta Energy is not responsible for the privacy
practices of, or any content on, those linked websites, and we have no control
over or rights in those linked websites. The privacy policies that apply to
those other websites may differ substantially from this Privacy Policy, so we
encourage individuals to read them before using those websites.
6 SECURITY
6.1. Alinta Energy
generally hold Personal Information in our electronic databases and in various
third party databases and platforms.
6.2. Alinta Energy is
committed to the security of your Personal Information and takes reasonable
steps to protect your Personal Information from misuse, interference and loss,
as well as unauthorised access, modification or disclosure.
6.3. Alinta Energy uses a
number of physical, administrative, personnel and technical measures to protect
your Personal Information, which include, but are not limited to:
·
implementing internal
processes and policies in relation to the collection, use and secure storage of
Personal Information and educating our personnel in relation to these
obligations
·
storing Personal
Information in secure, encrypted data centres
·
using secure networks or
encryption when transmitting electronic customer data and Personal Information
·
requiring the third parties
we engage to take adequate security measures and handle your Personal
Information in a manner consistent with the Privacy Act
·
regularly assessing the
risk of misuse, interference, loss, and unauthorised access, modification or
disclosure of that information
·
taking measures to address
those risks
·
having mandatory annual
training for all our staff on our privacy obligations, with a focus on how to
keep your information safe and secure.
7 REQUEST TO ACCESS
PERSONAL INFORMATION
7.1. You can request access
to the Personal Information that Alinta Energy holds about you at any time by
contacting us using the details at the end of this Policy. We will ask you to
verify your identity before we provide access to your information and we will
try to make the process as simple as possible.
7.2. Alinta Energy will
endeavour to respond within a reasonable period of receiving your request.
Where reasonable, we will provide you with a copy or details of your Personal
Information in the manner requested.
7.3. Sometimes Alinta
Energy may be unable to provide you with access to some or all of your personal
information (for example we reasonably believe that providing access would have
an unreasonable impact on the privacy of other individuals, would pose a
serious threat to the life, health or safety of any individual/to public
health/public safety or would be unlawful/prejudicial). Where this is the case,
we will tell you why.
8 REQUEST TO CORRECT
PERSONAL INFORMATION
8.1. Alinta Energy takes
reasonable steps to ensure that the Personal Information we collect, use and
disclose is accurate, complete, up to date and relevant.
8.2. If you believe the
Personal Information that we hold about you is inaccurate, incomplete or
outdated, please contact us using the details at the end of this Policy. We
will endeavour to respond within a reasonable period of receiving your request.
8.3. We will ask you to
verify your identity before we make any corrections.
8.4. If we do not think
that the information needs to be corrected, we will tell you why. If we do not
correct your Personal Information, you can ask us to include a statement (that
will be attached to that information) that you believe the information is
incorrect and why.
9
DESTRUCTION/DE-IDENTIFYING OF PERSONAL INFORMATION
9.1. When Alinta Energy no
longer needs the Personal Information collected for any purpose for which the Personal
Information may be used or disclosed, Alinta Energy will destroy/de-identify
the Personal Information in accordance with the Privacy Act requirements.
10 PRIVACY COMPLAINTS
10.1. If you believe that
we have breached the Privacy Act, or you wish to make a complaint about the way
we have handled your Personal Information, we encourage you to contact us using
the details at the end of this Policy.
10.2. Please include your
name, email address and/or telephone number and clearly describe your
complaint. We will respond within a reasonable period of receiving your
complaint.
10.3. If we receive a
complaint from you about how we have handled your Personal Information we will
determine what (if any) action we should take to resolve the complaint.
10.4. If we decide that a
complaint should be investigated further, the complaint will usually be handled
by a more senior officer than the officer whose actions you are complaining
about.
10.5. If you are not
satisfied with Alinta Energy’s handling of your complaint, you can lodge a
complaint with the Office of the Australian Information Commissioner (OAIC).
For further information regarding how to make a complaint to the OAIC, you can
visit oaic.gov.au/privacy/privacy-complaints.
11 HOW TO CONTACT US
11.1. Alinta Energy
welcomes your views about our Privacy Policy.
11.2. To ask us a question,
access your Personal Information, request a correction to your Personal
Information, make a complaint, or get a copy of this Policy, you can contact
Alinta Energy as set out below:
Postal
Address: Alinta Energy
PO Box
16196
Collins
Street West VIC 8007
Phone: 1300
193 986
·
For Privacy Matters
mark your correspondence Attention: Privacy Officer. The Privacy Officer’s
email is privacy@alintaenergy.com.au.
12 REVIEW OF POLICY
12.1. Alinta Energy’s
Privacy Policy will be reviewed by our Privacy Officer at least every two years
or more frequently if changes are required, including when there are
legislative changes or changes to our information handling practices. The next
scheduled review will be July 2025.
12.2. When we change our
Privacy Policy, we update it on our website. This Policy was last
reviewed in July 2023.