Privacy Policy

July 2023

Introduction

Protecting your privacy is very important to us. This Privacy Policy (Policy) sets out how we handle the personal information we collect.

NorthWestern Roads Group (NWRG) is the owner of the Westlink M7 toll road concession, in Sydney. This document governs the way we handle personal information. It does not cover the handling of personal information about any toll road account or toll road products you purchase. For information about the privacy of toll road retail customers please refer to the website of our preferred tolling provider, Linkt.

What Personal Information Do We Collect?

We collect information to provide services and information to our customers and to the community. We also collect information where we are required to do so to comply with the law.

The kinds of personal information that we collect and hold about you may include:

identifying information, such as your name and date of birth;
contact information, such as your postal address, email address and telephone number;
social media handles and other social media profile information that you make available to us or to the public;
recruitment-related information, such as your resume, work history, education and other qualifications or licences, character references, eligibility to work, screening checks (such as background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks);
information relating to your employment, such as your name and job title if you are employed by our contractors, suppliers and business partners;
information collected by security systems, including photographs and videos of you when you are in or near our sites or offices;
your licence plate number, insurance details, or photos and videos of vehicles (which may include occupants in vehicles or people on the roadside) involved in an incident on our roads;
information about use of your vehicle or your travel arrangements, such as other roads that you use, driving and travel patterns;
records of our communications with you, including any messages you send us, and information you provide to us in feedback or survey responses; and
device information, server log information, IP address, and location information

How Do We Collect Personal Information

We collect personal information about you in the following ways:

when you contact us by email, or by phone or when you submit information using the comments/feedback form on our website;
when you use our roads;
if you are involved in an incident or accident on our roads;
when you visit our roads, sites or our offices;
from our contractors, suppliers and business partners, for the purpose of conducting business with that individual or party;
when you apply for a job from us, we may collect personal information from you, recruitment consultants, your previous employers, your referees or other sources of relevant information, such as educational institutions, professional and trade associations, referees and publicly available sources;
by tracking your use of our websites and mobile applications;
from third parties who are entitled to disclose your personal information to us, including Transport for New South Wales or contractors and service providers who provide services in respect of our roads; and
from public sources

If you do not provide us with the personal information described above, depending on the nature of the information, we may be unable to provide you with services or assistance that you may request or require

Collection of Sensitive Personal Information

We will only collect sensitive information about you with your consent and if the information is reasonably necessary for our functions or activities or if we are otherwise allowed or required by law to collect that information.

Sensitive information includes (but is not limited to) information about your health, racial or ethnic origin, religious beliefs, membership of a professional or trade association, membership of a trade union, biometric information that is to be used for the purpose of automated biometric verification or biometric identification and criminal record.

What information do we collect about you when you work for us?

In addition to the information we may collect when you apply to work with us, we may collect the following personal information about you if you are an employee:

details about your training, performance and conduct;
details about your leave entitlements and employee benefits;
information to process your salary including your banking details, superannuation details and tax information;
personal information about your emergency contacts; and
information about your use of our facilities, IT (including software applications) and communications resources

We collect this information to train and manage our employees and to meet our legal obligations. Some of the personal information we collect is ‘sensitive information’ under certain privacy laws. For example, sensitive information we collect about our employees may include:

health information (e.g. in connection with road incidents, impact of construction work, sick leave, information relevant to COVID-19 vaccination status if the information is reasonably necessary for our functions or activities, or medical checks on job applicants and staff);
biometric information for the purpose of identity verification (such as your photograph to allow access to our premises);
union memberships and affiliations (such as membership information about your industry union); and
criminal record (e.g. police checks on job applicants and staff)

IP Address and Cookies

In order to monitor and improve the performance of our website, we may track your IP address, hardware settings, browser type, browser language and your session time. This information cannot be used to identify you and remains anonymous.

We may place a cookie in the browser files of your computer. The cookie does not contain any personally identifying information. It will however enable us to:

relate your use of the site to information that you have specifically and knowingly provided to us, such as through any services we may provide via our website; or
allow your browser to track searches you have performed on our website

You may configure your browser not to accept cookies (although this may disable or render unusable some of the features of our online services).

Why Do We Collect, Hold, Use and Disclose Your Information?

We collect, hold, use and disclose your personal information:

to conduct activities directly related to our business operations and to provide you with our services;
to safely operate our roads and to respond to accidents or incidents that happen on our roads;
to do business with you or your employer if you are a customer or service provider to us;
to consider you for a job when you apply to us;
to reply to you using any of the contact information provided to us;
where you have so requested, to provide you with an e-mail newsletter, and we will also provide you with the option to unsubscribe from our newsletter mailing list at any time;
to contact you by phone, fax, post, or e-mail regarding your enquiry / feedback / comments / complaints;
to compile demographics for the development of product offerings to provide you with services or conduct other business with you;
to comply with our legislative and contractual obligations, including our obligations to Transport for New South Wales; and
to undertake administrative or operational activities associated with managing and operating our roads

To Whom Can Your Information Be Disclosed?

We may disclose your personal information to:

our related bodies corporate and entities within our corporate group;
joint venture partners, business partners and successors of our business;
prospective purchasers of all or part of our business or shares in our company or a related entity;
contractors and service providers who provide us with services;
professional advisors who we engage to provide advice on our business;
government agencies, including Transport for New South Wales;
insurance companies;
other toll road operators; and
emergency services

On no account will we give, sell, trade, rent or otherwise supply personal user information to any other third-party organisation, except where you have consented to this, where it is reasonable to do so in the provision of services to you, or when it is otherwise authorised by law.

We may be required to provide your personal information where the law requires, for example, in response to a subpoena, warrant, or request from a government law enforcement agency, or as required under legislation and regulations applying to our roads.

Cross-border Disclosures

We may disclose your personal information to recipients that are located outside Australia to perform services in connection with our roads.

We may disclose personal information to overseas contractors and may use off-shore servers for the purposes of data storage. We have engaged contractors in the Philippines, and certain other countries, and may disclose certain personal information to those contractors.

We have an obligation to take reasonable steps to ensure that any overseas recipient does not breach the Australian Privacy Principles in relation to the personal information.

How do we secure your information?

We implement safeguards and security measures to protect personal information we hold about you from risks such as misuse, interference, unauthorised access, modification, or disclosure. We use a number of physical and electronic measures to protect your information as well as training our staff (and contractors) in our internal procedures and systems with respect to the handling of personal information. We also take steps to conduct checks on our third-party providers.

How can you access and correct your information?

You have a right to access the personal information that we hold about you. You may do so for Westlink M7 by emailing us.

We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with access to this information.

When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.

In some circumstances it may not be possible for us to provide you with all of your personal information, or an exception to access under the Privacy Act may apply. For example, we may not be able to give you access if it would unreasonably affect someone else’s privacy. If we do not provide access to the personal information held about you, we will tell you why.

We have an obligation to take reasonable steps to only hold personal information about you that is accurate, complete, up-to-date, relevant, and not misleading.

If you think that any personal information we hold about you is inaccurate, you may contact us. We will take reasonable steps to make sure that the information is corrected.

We reserve the right to refuse to correct your personal information in some circumstances. If we refuse to correct any personal information about you, and we cannot reach a subsequent agreement, you may request that a note or statement regarding the correction request be attached to the file that contains your personal information.

Questions, concerns, and further information

If you want to talk to us about the way we handle your personal information please contact our Privacy Officer by emailing us or writing to us at:

Westlink M7
Attention: Privacy Officer
PO Box 236
Horsley Park NSW 2175

Please ensure that your correspondence:

includes a method for us to contact you; and
clearly describe your concerns

We will aim to respond as soon as we can. If you are not satisfied with our response, you may also contact the relevant regulator such as the Australian Information Commissioner or the Tolling Customer Ombudsman. As at the date of this Privacy Policy, the contact details are as follows:

Tolling Customer Ombudsman	Office of the Australian Information Commissioner
PO Box 7095	GPO Box 5218
Hawthorn North VIC 3122	Sydney NSW 2001
Phone: 1800 145 009	Phone: 1300 363 992
Email: admin@tollingombudsman.com.au	Email: enquiries@oaic.gov.au
Website: http://www.tollingombudsman.com.au	Online: https://www.oaic.gov.au/privacy/privacy-complaints/

Contact Us

If you have any questions or comments about our privacy policy, or any concerns or complaints regarding the treatment of your personal information, please feel free to contact us by emailing us.

Westlink M7 Privacy Policy