We collect certain kinds of personal information regularly as part of the work we do in resolving disputes and running our office. We usually collect information from our customers (people who contact us with a complaint to resolve) when they first get in touch with us or throughout the course of resolving a complaint (and sometimes at other times when we are contacted by customers generally). We also collect relevant personal information of our team members and potential recruits.
Customers
When a customer calls us, we may ask for personal information on the phone, in person, or by letter or email. We may monitor or record calls for case management, training and coaching purposes. Customers can tell the operator if they don’t want us to do this.
We collect personal information from our customers when they make a complaint to us so that we can properly assist them in resolving it. We need this information to provide our services. The types of information we collect include (but may go beyond if needed):
- their name[1]
- their contact details (e.g. current and previous addresses, telephone numbers, email address)
- how many people live at the home the complaint relates to
- account information (current and past) relevant to the dispute
- information the energy or water supplier or distributor gives to us about the customer
- other information provided to us by the customer, supplier or distributor (which might include photos of the property or meter and the like)
- information from collection agencies
- other demographic information (which is provided at the customer’s choice and not a prerequisite to service)
- information about any special needs of the customer (for example, if they need an interpreter).
Use by our team members
On a day-to-day basis any of our team members with responsibility for receiving and responding to enquiries (including responding to comments or messages on social media), conducting investigations or undertaking administrative activities (and any team member responsible for supervising activities) may have access to personal information.
Similarly, other team members who work on planning, managing systemic issues, creating policy or reporting may have access to personal information for the purposes of collating statistics, reporting (including case studies with identifying information removed, presentations, training and quality checking), or developing or researching policies and procedures. The information used may include demographic information to better target our community engagement work, to report to other regulators and Government bodies, and otherwise to assist in developing our processes and services. Any of the work produced by these team members will only be published if the information is de-personalised.
Other team members responsible for the managing of information technology systems may have access to personal information for the purposes of maintaining and creating the platforms on which the data is stored.
Customers can tell us if they do not want us to use their personal information in these ways, or if they want more information on how we manage their personal information.
Information provided to other entities
As indicated above, we will also disclose personal information given to us by customers to the customer’s energy or water supplier/distributor (the entity complained about) so that they can respond to the complaint or seek clarification of an issue or further information. This is required by the Act. We may give access to this information through an online portal or via email or post.
A customer’s personal information may also be provided to government entities with a legitimate interest in the information, provided EWOQ has the customer’s consent or is required by law to do so, for example, by force of a subpoena.
If a complaint is not within EWOQ’s jurisdiction we may, with the customer’s consent, refer the complaint to government entities or other ombudsman schemes which have a legitimate interest in the information, for example:
- Queensland Office of Fair Trading
- Queensland Competition Authority
- Department of Energy and Public Works
- Department of Regional Development, Manufacturing and Water
- Australian Competition and Consumer Commission
- Australian Energy Regulator
- Queensland Ombudsman
- Australian Energy Market Commission
- Office of the Australian Information Commissioner.[2]
Customer feedback and surveys
A customer’s personal information may also be used for undertaking internal or external surveys. Customers are given an opportunity in speaking with our team members to consent to be involved in the surveys or advise EWOQ that they do not wish to be surveyed.
Information which identifies customers who have consented to the survey (name and contact details only) may be provided to an external company solely for the purpose of that company conducting surveys on behalf of EWOQ.
Where stated on a survey, a customer’s responses may be provided to members of our scheme (i.e. retailers and network service providers) for use in quality control and in improving services. This includes entities which do not have a direct relationship with the customer (e.g. retailers other than their own). We will only provide the substantive responses and not the names or contact details of the customer, but if the customer’s responses have identified themselves then this information will not be removed before the information is given to the members of our scheme.
We use the information our customers provide in surveys to improve our processes and review our performance.
Our team members and recruits
On a day-to-day basis some of our team members (those who have appropriate authorisation and operational need) have access to personal information of other team members.
Employee information
We collect and store certain employee-related information because we are required to by law. [3]Employee records include details about personnel, payroll, recruitment, performance and other records. The information collected may include names, dates of birth, occupation, employee identification number, general medical information, qualifications, next of kin, relationship details, details of pay and allowances, travel records, personal financial information, leave details, timesheet information and overtime records, work reports, employment history, staff awards, disciplinary investigations and actions, performance assessments and criminal convictions.
The above information is used for our internal human resource management, including assessing whether employees are complying with policies and procedures. This information may be accessible by certain team members, including the employee’s manager and line managers and others as required and appropriate. This information is stored and kept confidential otherwise.
Certain employee information relating to payroll, leave, employee requests and contact information is stored in online portals operated by third party providers. These third-party providers are subject to confidentiality obligations and the IP Act under the terms of their engagement.
Recruitment information
Similarly, we keep personal information provided by potential recruits, including applications to work with us, records relating to referee checks, interview notes and selection panel assessments. This information is collected and used so that we can select employees fairly and is provided to members (and relevant administrative assistants) of selection panels (including possible third-party panel members) for use in deciding the successful candidate. The relevant details about a person’s application may be disclosed to a person’s nominated referees in the event their application warrants a referee check.
Recruitment information may be processed and handled through third party platforms, such as other government services and Springboard (as part of SmartJobs). Our human resources contractors may have access to information provided as part of recruitment processes for use in assisting us with evaluating applicants.
As part of our screening process, criminal history checks may be undertaken in accordance with a consent form from applicants. This information is used in hiring decisions and then deleted. A record is retained that a search was undertaken without the search results.
Copies of identification documents may be obtained as part of the hiring process to verify identity and other information. This information is deleted once a hiring decision is made.
Limited and specific personal information is disclosed to third parties as appropriate, including superannuation companies as nominated by the team member, the Australian Taxation Office, organisations in receipt of payroll deductions and external medical/emergency personnel. Otherwise information is only disclosed to third parties with the permission of the team member or as required by law (for example, to the Crime and Corruption Commission in connection with allegations of official misconduct).
Other information
We also store other kinds of information (some of which may be personal information) to assist us in running our workplace. This includes content like financial management information, complaints, mailing lists, details of stakeholder groups, communications and publications, audit outcomes, security and general management issues. We collect and store this kind of information in accordance with the IP Act.
[1] While a customer can choose to stay anonymous, it is more difficult for us to investigate an anonymous complaint (depending on the details provided) and we will not be able to advise them of the outcome.
[2] The EWOQ is a recognised external dispute resolution scheme (EDR) under section 35 of the Privacy Act 1988 (Cth). Subject to the Energy and Water Ombudsman Act 2006, EWOQ will receive, investigate, facilitate the resolution of, make decisions and recommendations for, and report on, complaints within its scope about acts or practices of EWOQ scheme participants that may be an interference with the privacy of an individual under subsections 13(1) and/or 13(2) of the Privacy Act 1988 (Cth). EDR privacy complaints may be referred to the Office of the Australian Information Commissioner.
[3] Under the Public Service Act 2008 and the Public Service Regulation 2008.