Privacy

Privacy

We appreciate that like most people, your privacy is very important to you. Your privacy is also extremely important to us.

We have strict systems in place to make sure your personal details stay protected, and are only used for the right purposes. In every instance we collect, store, use and disclose your information professionally and respectfully.

So you can feel confident about sharing your personal details with us, we describe how we maintain your privacy as well as how you can access and control the personal information you give us.

Synergy has designed and implemented its privacy policy, systems and procedures with the intention to follow the requirements of the Australian Privacy Principles.

What this policy covers

This policy covers the collection, storage, use, disclosure and security of your personal details. We explain how and when we collect your personal information, what that information is used for, who uses it and when it may be disclosed to other parties.

The policy also explains how you can access your details and control your own personal information.

This policy also includes our Credit Reporting Policy which details how we manage your credit information and credit reporting information. We describe what we mean by this sort of information in the Credit Reporting Policy heading below. The credit reporting bodies that Synergy uses include Veda Advantage Information Services and Solutions (Veda) and Dun & Bradstreet (D&B). A copy of Veda’s or D&B’s credit reporting policy can be obtained by contacting them directly via their websites. You should be aware that:

credit reporting bodies may include the information in reports provided to credit providers to assist them to assess your credit worthiness;
we may disclose information about an overdue payment or serious credit infringement to a credit reporting body;
you can contact us if you would like to access or correct your information held by us; or if you have a query or concern about our privacy practices;
you can request a credit reporting body not to use your credit reporting information for the purposes of pre-screening or direct marketing by us; and
you can request a credit reporting body not to use or disclose your credit reporting information if you believe on reasonable grounds that you have been (or are likely to be) a victim of fraud.

What is personal information?

"Personal information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

Details such as your name, address, phone numbers or email address are all considered personal information. Other types of personal information we collect can include amongst other information:

Financial details, including your credit card number or bank account number;
Information that uniquely identifies you, like your date of birth or product purchase details, such as the date you contracted with Synergy; and
Your usage information relating to power supply or any other product or service.

We need this information to be able to give you the best service possible. If you choose not to provide the personal information we ask you for, we may not be able to offer our products and services to you.

How and why we collect and store your personal information

We only collect your personal information to allow us to conduct our business functions and to market and sell our products and services.

Wherever it’s possible, we try to collect personal information directly from you. Usually this is done over the phone, when you fill out an application form or contract, when you buy our products and services or request information about us, when you visit or contact us through our website, or when you speak to us in person.

Sometimes, we’ll also confirm and share your details with external agencies such as:

The Office of Seniors' Interests (to confirm entitlements to concessions);
Centrelink (to confirm entitlements to concessions);
WA government departments or other government agencies such as ASIC, WA Police or the Australian Tax Office who make requests (for the purposes of responding to those requests); and
The Energy and Water Ombudsman's Office (to investigate and respond to small use customer complaints).

Occasionally we’ll collect your personal details from sources such as real estate agents, builders, brokers and energy consultants or powers of attorney — but only when it is unreasonable or impractical to collect this information directly from you, or if you’ve authorised them to provide that information, or if we are otherwise permitted by law to do so.

It’s normal business practice to collect or receive personal information from external agencies, when it’s necessary for us to be able to provide you with our energy products and services. We also recognise the obligations under privacy legislation in relation to what is defined in the legislation as ‘Sensitive Information. Sensitive information may include, for example your membership with a professional or trade association. This will only be collected if needed, and only if you’ve consented to providing that information.

Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

Most of the information we collect is stored electronically, but some of it is stored in hard copy. In either case, the information is stored securely and in line with commercial standards.

How we use your personal information

The main reasons we use your personal details are to establish, maintain, service, disconnect and bill your energy products and services. We could also use your personal information:

to build a relationship with you;
to communicate with you;
to provide you with information, products or services you have requested;
to assist customers by providing them with information and support;
to help us research the needs of our customers and to market our products and services with a better understanding of your needs and the needs of customers generally, including after you no longer receive services from us (unless you have opted out of receiving further contact from us);
for internal accounting and administration and to manage and administer any account you may hold with us;
for debt recovery;
to predict where we might be at risk of credit default by our customers, and take action to manage that risk;
for our regulatory reporting and compliance obligations;
for legal requirements;
to help us identify and keep you informed about other Synergy products and services that you could benefit from;
to provide advertising material to you regarding us, our clients, and other business partners;
to personalise and customise your experiences with our website;
to process any job application submitted by you;
to share your personal information with additional persons you have permitted to be added to your account as authorised contacts, our related entities, business partners and third party service providers, to assist us in these processes;
if you are a contractor or supplier of goods or services to Synergy, to communicate with you about and administer you or your employer's engagement with Synergy, and otherwise as specified in this privacy policy.

So that we can communicate effectively with you, we may also provide information about Synergy’s and related company's products, services, initiatives and promotions in newsletters, magazines and inserts with your energy bill.

We may collect and use your personal information for other purposes not listed above. If we do so, we will make that purpose known to you at the time we collect or use your personal information.

We do not collect or use your personal or sensitive information unless it is reasonably necessary for, or directly related to, our activities.

Information collected through our website

We aim to make our website informative and functional, but above all we’re committed to protecting your privacy.

To use many of the website’s features, you’ll be asked to give us some personal information. Rest assured we’ve taken a number of measures to protect this information in a secure online environment.

To use some of the customer services and features in this website, we need you to enter standard personal information about yourself and your energy account. We collect and securely store this information so we can accurately identify you in the future, and contact you when we need to. For instance, we could ask for your address details to send you a brochure, your contact details for a competition entry, or your bank details so you can pay your energy bill online.

Depending on what other information you choose to provide through the website, we may also collect the following information from you, which we will only use for the purposes set out in, and in accordance with, this privacy policy and applicable laws:

Data in relation to your consumption and use of our products;
Data in relation to your spending with us and supply history;
Your equipment information;
Your industry information;
Your annual sales turnover information;
Your appliance profiles at home and their associated usage;
Your household profile; and
Your energy efficiency preferences and practices.

Information logged on our website

The types of information we record for administration, statistical, marketing, reporting and maintenance purposes include:

Browser type and operating system of your computer;
Your internet service provider (ISP), and its approximate geographic location;
The number of users visiting our website, the number of pages viewed and the paths taken between pages;
The date, time and duration of a visit;
The address of any referring web site; and
Your computer's IP (internet protocol) address.

Social media

Synergy also uses third-party websites for interactive information sharing and to connect with customers. Examples include social networking platforms such as Facebook, Twitter, LinkedIn and YouTube.

We recommend you read any terms and conditions (including any privacy statements or policies) that apply to any third-party web service, especially the terms and conditions relating to the handling of your personal information, when using these social media platforms to interact with Synergy. These third-party privacy statements and conditions may allow those third parties to use your personal information in ways that will be different to the way Synergy uses and discloses your personal information. They will prevail over this privacy statement to the extent of any inconsistency but will not change the way in which Synergy uses your personal information.

We recommend that you do not use a public-facing social media channel, such as Facebook, to provide us with your personal details or disclose these personal details in any query or issue raised through that forum. This is necessary in protecting your privacy and keeping your account details private, preventing identity theft or unauthorised people accessing your Synergy account.

Examples of personal details you should not provide on these social media channels include your home address, birth date, middle or maiden name, Synergy account number or any details used in an ID check by Synergy to verify who you are.

We encourage you to keep this personal information away from the public eye by contacting Synergy through direct or private messages, email or the phone.

Links to other sites

Some sections of the Synergy website have links to other websites. We review these sites before linking to them, but the content and privacy practices of these other websites is outside our control and our privacy policy does not affect them.

Searches

We collect and store the words you enter into our site's search field, to learn what information people are generally looking for. This helps us improve the site by including the information you ask for. Unless personal information is used as part of a search, these search words aren’t connected to any kind of personal information.

Our systems

We’ve established systems and procedures to protect your privacy whenever we collect, use, store or disclose your personal information. Our security measures are designed to follow industry practices in securing access to your account or personal information.

Direct marketing and your privacy

As well as the information you receive with your bill, we may occasionally contact you directly with related energy news, information, and special offers from Synergy and other businesses. You consent to us sending you such information including by means of direct mail, telemarketing, fax, email, SMS and MMS messages, and other digital channels.

If you don’t wish to receive direct marketing information from us (other than apart from what you receive normally with your bill), you can contact us and make a request using the contact details specified at the end of this policy. We’ll need a short processing period to action your request. Further, any direct-marketing material sent to you by Synergy includes the opportunity to opt out of any future marketing communication.

Credit Reporting Policy

This part of the policy provides details about how we manage your credit information and credit reporting information. “Credit information” is the basic category of personal information in the credit reporting system. It includes identification information such as your name, sex, address, date of birth; default information about overdue payments and information about court proceedings. Credit information does not include any information that privacy legislation would classify as 'sensitive information'. So, for example, information such as a criminal record or – e.g. medical history is not included.

Ordinarily, we collect credit information directly from you. We may also collect credit reporting information about you from a credit reporting body.

We do not use the credit information or credit reporting information to derive any additional information such as a credit score.

We collect, store and use credit information and credit reporting information about you to allow us to conduct our business functions and sell our products and services. The reasons for which we may use that information are the same as those set out in the section on 'How we use your personal information'. This includes assessing your application, debt recovery, managing our risk of credit defaults and administrating or managing any account you may hold with us. All information is stored securely.

If your account remains overdue for more than 60 days, we may give credit information about you to a credit reporting body. This information will allow the credit reporting body to create or maintain a credit information file containing information about you. The information that we disclose about you to a credit reporting body is limited to:

Identification information including your name, sex, address (and your previous two addresses), date of birth, name of employer and drivers licence number;
Amounts over $200 that are overdue by more than 60 days and for which debt collection action has started;
Advice that your payments are no longer overdue in respect of any default that has been listed;
Information that, in our opinion, you have committed a serious credit infringement (that is, acted fraudulently or shown an intention not to comply with your credit obligations); or
Dishonoured cheques – cheques drawn by you for $150 or more which have been dishonoured more than once.

In certain circumstances, we may need to disclose your credit information to others. The people to whom we may disclose your credit information and the reasons for such disclosure are the same as those set out in 'The people who use your personal information' section of this policy. Your credit information and credit reporting information may be transferred, stored, processed or used overseas by us or third parties. Please see the 'Overseas disclosures' section of this policy for further information about the countries in which your information may be disclosed.

The following sections of this privacy policy apply to the credit information and credit reporting information in the same manner as they apply to personal information:

The people who use your personal information

Only a select number of Synergy staff have authority to access your information, and only to the extent to allow them to carry-out their jobs.

We may also need to disclose your personal information to others who are part of our processes to deliver the products and services you want from us and for the purposes referred to in this privacy policy.

Those people may include additional persons you have permitted to be added to your account as authorised contacts, our related entities, third parties that provide products and services to us or through us, including call centre operators, billing and mailing houses, debt collection agencies, network operators, customer and market research agencies, marketing agencies, third party product and service providers, IT service providers such as our website host, data storage providers, analysts or software application providers, financial institutions and government or regulatory agencies or authorities. Generally, we'll only disclose your personal information to these parties:

for the purposes set out in this privacy policy or any agreement you enter into with us;
in circumstances permitted by the Australian Privacy Principles;
if we are otherwise required or authorised by law; or
if the disclosure is made with your consent.

Overseas disclosures

Some of your personal information may be transferred, stored, processed or used overseas by us or by our third party service providers. In particular, as at the date this privacy policy was most recently updated, your personal information will be disclosed to recipients in the USA, Japan, Philippines, New Zealand, India, Germany and other countries from time to time. This may happen if our related entities are overseas, if our service providers are located overseas, or if transactions, information, services or products have an overseas connection. Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

You agree to the disclosure and use of such personal information in accordance with this privacy policy, and consent to its disclosure overseas and its use by third parties, including our related entities and service providers, in the USA, Japan, Philippines, New Zealand, India, and such other countries in which those parties or their computer systems may be located from time to time, where it may be used solely for the purposes described in this privacy policy, without us being responsible for such use (or for any breach).

Keeping your personal information correct and up-to-date

So that we can deliver the best possible service to you, it’s important that we maintain accurate and up-to-date information about you. We use our best efforts to make sure the personal information we collect, use and disclose is correct, complete and up-to-date.

The best way to get this result is to let you correct or change the personal information we store for you. So if you’d like to make any changes to your personal information, simply contact us and we’ll carry out your instructions.

Access to your personal information

You’re welcome to ask for a written copy of the personal information we hold about you, at any time. To do this, simply contact us using the contact details specified at the end of this policy with your request and include your contact details. We’ll contact you to establish proof of your identity before sending you these details.

We’ll respond to your request for this information as quickly as possible. At a minimum, we’ll confirm receiving your request within five working days of it arriving with us. Synergy may charge for the reasonable costs we incur in providing you with this information.

Collection of Information Statement

In order to be able to provide our products and services, we need to collect personal and credit information about you which we will use in accordance with our privacy policy.

We may disclose your personal or credit information to other parties, including our related companies, third party providers, and other third parties, as specified in our privacy policy.

If you apply to us for commercial credit, we may collect or disclose commercial credit information about you to credit reporting bodies (CRBs) for the purpose of assessing your application for commercial credit, or to collect overdue payments. We may also disclose consumer or commercial credit information to CRBs including the overdue payments, when those payments have been paid, or a serious credit infringement.

The third parties referred to in this statement may be located overseas, including the USA, Japan, Philippines, India, and New Zealand.

We may use and disclose your personal or credit information for direct marketing purposes, unless you opt-out.

Our privacy policy sets out information about how we manage your personal and credit information, how you can opt out of direct marketing, how you can access and correct the information we hold about you, and the process for complaining about a privacy breach. Our privacy policy also includes important information about credit reporting including the details about the CRBs to whom we may disclose your credit information, the information that CRBs hold, and how you can request CRBs not to use or disclose your information for pre-screening or when you consider yourself to be victim of fraud. You can request a copy of the statement setting out the important credit reporting information by contacting us.

Changes to our privacy policy

This is Synergy’s current privacy policy. From time to time, we may need to change our privacy policy. If we do this, we’ll give you notice of the new privacy policy by publishing it on the Synergy website.

What to do if you have a question, problem or complaint about our use of your personal information or this privacy policy

If you:

feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this privacy policy and you would like to make a complaint;
would like to get in touch with us about direct marketing;
would like to access your personal information held by us;
would like to correct your personal information held by us; or
have a query or concern about this privacy policy,
please contact our Customer Service Representatives by:
phone 1800 208 987;
fax 08 6212 1848;
mail GPO Box K851, Perth WA, 6842.

We will investigate your queries and complaints within a reasonable period of time and will notify you of the outcome of our investigation.

Last updated: February 2016