Last updated: 27/10/2017
Transurban respects people's privacy. Transurban is bound by a range of laws protecting privacy, which may include the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).
- each of Transurban International Limited (ABN 90 121 746 825), Transurban Holdings Limited (ABN 86 098 143 429) and Transurban Holding Trust (ARSN 098 807 419) by its responsible entity Transurban Infrastructure Management Limited (ABN 27 098 147 678) (the 'Stapled Entities');
- each company in which the Stapled Entities, whether individually or collectively, own (directly or indirectly) more than 50% of the voting shares; and
- each trust in which the Stapled Entities, whether individually or collectively, own (directly or indirectly) more than 50% of issued units,
but does not include Transurban Queensland;
Transurban Road means any road or part of a road in Australia that is, has been or is proposed to be operated or managed by Transurban, including CityLink, Hills M2, Lane Cove Tunnel, Eastern Distributor, Westlink M7 and Cross City Tunnel; and
personal information means information or an opinion about an identified individual, or about an individual who is reasonably identifiable.
What personal information does Transurban collect and why?
Transurban collects the personal information it needs:
- to provide services and information to its customers and the community;
- for its business operations (including the operation of Transurban Roads); and
- to comply with the law.
If you choose not to provide certain personal information to Transurban, Transurban may not be able to fulfil your request or provide you with certain services or information relating to Transurban.
The main types of personal information collected by Transurban are name, contact details, identification details (e.g. date of birth), organisation, employment, positions held, preferences, comments, feedback, enquiries and records of Transurban's communications and dealings with you (including by phone, email, in-person and online). Transurban sometimes collects other types of information in particular circumstances. Some examples of these circumstances are set out below, including the main purposes for which personal information is collected in those circumstances. Another section later in this policy is headed 'Online services' and contains further details of the information Transurban collects online.
- To operate Transurban Roads and to provide services to you
Transurban may collect additional information about you, such as:
- payment and billing information;
- credit card number;
- drivers licence number;
- licence plate number;
- vehicle make, model, year, colour, registration and acquisition date;
- images and video footage of vehicles on roadways and occasionally this may include the occupants in vehicles or people on the roadside; and
- information about your use of Transurban services and Transurban Roads and other roads of interest to Transurban, including the date and time of travel.
Transurban collects this information to supply its services, operate and improve Transurban Roads, and recover its tolls.
- To comply with the law
Transurban may collect information about you as required or permitted by law. For example, Transurban is required by law to keep certain records, including information about the payment and non-payment of tolls. The laws under which Transurban collects personal information include:
- roads laws such as the Melbourne City Link Act (Vic), Road Safety Act (Vic) and Roads Act (NSW);
- the Fair Work Act and Superannuation Guarantee (Administration) Act;
- the Income Tax Assessment Act and other tax laws;the Corporations Act; and
- occupational health and safety acts and workers compensation acts.
- To assist with queries and feedback and engage with stakeholders
You are always welcome to provide Transurban with comments, queries and feedback in relation to Transurban's products and services, and current or proposed Transurban Roads. Depending on the nature of your issue, Transurban may collect additional personal information including details of any property which may be affected by a Transurban Road, the languages you speak, your family and living circumstances, how best to manage communications with you and information about your dealings with Transurban. This allows Transurban to respond to requests for information about customer accounts, its services and Transurban Roads and to carry out community engagement, investigation and assessment activities in relation to Transurban Roads.
- As part of Transurban's general business operations
Transurban also collects personal information about individuals who invest in Transurban or who are contracted to, or employed by Transurban's suppliers (including third party service providers), business partners, agents and customers.
As required, this information may include an individual's name, contact details, and other information necessary for Transurban to conduct business with that individual or party.
- To consider you for a job with Transurban
Transurban may collect certain information from:
- any recruitment consultant;
- your previous employers; and
- others, including educational institutions, professional and trade associations, referees and publicly available sources, that may be able to provide information to Transurban,
to assist Transurban in its decision on whether or not to make you an offer of employment or engage you under a contract.
This information may include information about your working history, qualifications, skills, character and relevant records and screening checks (e.g. background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks). As necessary and where appropriate, Transurban may require prospective staff to undergo certain medical checks.
- When you work for Transurban
In addition to the information types referred to in the previous section ('To consider you for a job with Transurban'), Transurban may collect information about staff members' training, terms and conditions, staff benefits, emergency contact details, performance, conduct, use of Transurban's IT and communications resources, payroll matters, leave and tax/financial affairs. Transurban collects this information to train and manage its workforce and meets its legal obligations.
- Collection of sensitive personal information
Some of the personal information Transurban collects is considered 'sensitive information' under certain privacy laws. For example, sensitive information Transurban collects may include:
- health information (e.g. in connection with road incidents, impact of construction work, sick leave or medical checks on job applicants and staff);
- criminal record (e.g. police checks on job applicants and staff); and
- political opinions (e.g. whether you support a major infrastructure project such as a new Transurban Road).
Subject to privacy laws, Transurban may sometimes collect sensitive information about you from a third party who holds sensitive information about you. If you think Transurban has received your sensitive information in error, please contact Transurban using the details below.
How does Transurban collect personal information
Transurban will generally collect information directly from you. However, Transurban may collect information about you from a third party, such as:
- your employer, referees, representatives, joint account holders and family members;
- government road and traffic authorities (including VicRoads and New South Wales Roads and Maritime Services);
- service providers to government authorities (e.g. companies that provide traffic camera services to police);
- other Australian toll-road operators;
- Transurban Queensland;
- researchers; and
- suppliers of information products and services (e.g. companies that consolidate data from multiple public sources).
Transurban may supplement the information it collects with information from other sources, such as generally available publications and information available online and through social media platforms and providers.
Transurban may also collect personal information through:
- automatic incident detection systems (including traffic management and safety cameras);
- vehicle registration detection systems;
- electronic toll collection systems (such as an 'e-TAG' or 'Tag' attached to an individual's vehicle); and
- mobile applications and websites, including where you have agreed to disclose information about your location while using a Transurban website or App.
How does Transurban use and disclose personal information?
Transurban generally uses and discloses personal information:
- for the purposes for which it was collected;
- in order to provide and improve Transurban's products and services;
- in order to operate and improve Transurban Roads (including as described above) and Transurban Queensland roads as required, and to undertake administrative or operational activities associated with designing, constructing, managing and operating Transurban Roads;
- to maintain its relationship with you;
- to verify your identity and personal information;
- to maintain and update Transurban's records;
- to calculate and recover tolls and fees;
- for debt collection and enforcement purposes;
- to investigate or to pursue any legal claim that Transurban may have against you;
- for road safety purposes;
- to undertake traffic planning and vehicle management services;
- to meet our obligations and perform Transurban's functions under applicable laws and agreements;
- to detect, prevent and investigate any fraud or crime (or suspected fraud or crime);
- to notify you of changes to Transurban's tolls, fees, charges, agreements, products or services; or
- as otherwise required or authorised by law.
Transurban may disclose your personal information to its related bodies corporate, including Transurban Queensland. It will do so in accordance with the requirements of the Privacy Act.
Transurban exchanges certain personal information with other Australian toll-road operators. For example, when an individual opens an account to access a Transurban Road, Transurban will use and disclose the individual's personal information for the purposes of facilitating their travel on Transurban Roads and any other Australian toll-roads with which Transurban has 'roaming' arrangements in place, and to allow the operators of those roads to obtain payment for travel.
When Transurban collects personal information, it may sometimes also use that information to carry out consumer, market, community and traffic research, compile demographics and perform other analysis so that Transurban can develop and implement initiatives to improve its services, improve the design, construction and operation of Transurban Roads and identify people likely to be affected by or interested in Transurban Roads and services. As part of conducting Transurban's business, personal information may also be used to maintain and develop Transurban's business systems, including testing and upgrading them.
Transurban may collect, use and disclose your personal information for marketing purposes. Transurban may send you promotions, offers and other marketing materials on Transurban products and services, or the products and services of other people that Transurban thinks may be of interest to you. This information may be sent to you by email, SMS or by other means. You can unsubscribe from receiving these types of promotional communications by:
- following the 'unsubscribe' link in the communication;
- changing your account settings; or
- contacting Transurban using the details below.
Unsubscribing from promotional communications will not stop service related communications from Transurban, such as administrative alerts in relation to your account and notifications in relation to road closures.
Transurban may de-identify information about an individual so that the information can no longer be related to that individual. Transurban may then use and disclose that de-identified information in the course of its business. Transurban may also aggregate information on the use of its services and Transurban Roads (for instance, traffic information) in such a way that the information can no longer be related to the specific individuals. Transurban may then use and publicly disclose such aggregated information in the course of its business.
Where appropriate, Transurban may handle personal information relying on exemptions that are available under applicable privacy laws, including, for example, the employee records exemption in the Privacy Act and provisions in the Privacy Act concerning the sharing of personal information among related bodies corporate.
Disclosing personal information
For the purposes described in this policy, Transurban may disclose personal information:
- to Transurban Queensland;
- under information sharing arrangements with the operators of other Australian toll-roads;
- to Transurban's suppliers, service providers, professional advisers and agents. The types of suppliers Transurban may disclose personal information to include:
- call centre operators;
- mailhouse organisations;
- marketing, advertising and information service providers including social media services and data supply companies;
- contractors that own or operate distribution outlets (such as electronic kiosks);
- banks, financial institutions and payment processing providers;
- towing, roadside support and maintenance and logistics contractors (e.g. if you or your vehicle are involved in or near a road incident);
- engineers and surveyors;
- researchers and investigators;
- share registry providers;
- recruitment, payroll, superannuation, staff benefits, surveillance and training providers;
- debt collection companies and credit reporting bodies;
- Australia Post and delivery supply contractors; and
- information technology suppliers that provide support, maintenance and upgrade services for Transurban systems;
- to government agencies including emergency services;
- any entity responsible for the collection of tolls or the taking of enforcement action concerning use of Transurban Roads;
- to anyone who acquires or considers acquiring Transurban's assets or business (or any part of it);
- where an individual to whom the personal information relates has otherwise consented; or
- as otherwise required or permitted by law. For example, Transurban may disclose information in response to a subpoena, warrant, or request from a government law enforcement agency, or as required under legislation and regulations applying to specific Transurban Roads. Transurban may disclose information to AUSTRAC under applicable anti-money laundering legislation if you have an account balance of $5,000 or more.
Under the Corporations Act, Transurban is required to make limited shareholder details available to members of the public on request.
Transurban may disclose information to recipients that are located outside Australia.
Transurban may disclose personal information to overseas contractors, and may use off-shore servers for the purposes of data storage. Transurban has engaged contractors in the Philippines, the United States, France, India and certain other countries, and may disclose certain personal information to those contractors.
Transurban may also disclose certain personal information to its related entities in the United States, although such information will typically only relate to employees and internal corporate matters and not customer information or the operation of Transurban Roads in Australia.
This section applies to Transurban's websites, apps, email communications, social media profiles and other online services (together, 'Online Services').
Transurban's Online Services may also detect and use your IP address or domain name for internal traffic monitoring and capacity management purposes or to otherwise administer the Online Services. No personal information is obtained. Rather, the patterns of usage of visitors to the Online Services may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user traffic patterns.
From time to time, Transurban may use third-party online services to collect personal information such as your name and email address or phone number to administer online competitions, customer feedback and surveys.
Transurban uses a number of physical and electronic measures to protect personal information. Transurban:
- restricts access to its electronic databases;
- maintains firewalls; and
- encrypts certain data where practicable to do so.
Please note, however, that the internet is not a secure environment. Although all care is taken, Transurban cannot guarantee the security of information provided to it via electronic means.
Access and correction
You have a right to access most personal information that Transurban has about you. In some circumstances it may not be possible for Transurban to provide you with all of your personal information, or an exemption under the Privacy Act may apply. For instance, Transurban may not provide access to information if disclosing that information would impact on the privacy of another individual. Where Transurban will not provide access to personal information held about you, Transurban will tell you why.
When you request access to personal information, Transurban may need to take measures to verify your identity before providing you with such information. If you think that any personal information Transurban holds about you is inaccurate, you may contact Transurban Customer Relations. Transurban will take reasonable steps to make sure that the information is corrected. Transurban can correct most personal information over the telephone, but correction requests may need to be made in writing in some cases.
- include your contact details (such as email address, name, address and telephone number); and
- clearly describe the complaint.
Transurban Customer Relations will investigate the complaint and respond promptly. If you think that Transurban has failed to resolve your complaint satisfactorily, you
PO Box 7095
Hawthorn North VIC 3122
Alternatively, you can complain to the Office of the Australian Information Commissioner by:
GPO Box 5218
Sydney NSW 2001
For access and correction enquiries, and complaints, please contact Transurban Customer Relations using the contact details provided below.
New South Wales
Locked Bag 5002
Parramatta, NSW 2124
Locked Bag 5002
Parramatta NSW 2124
CityLink Customer Resolutions
Locked Bag 28
South Melbourne, VIC 3205