CICL Privacy Policy
1. Purpose of the Policy
Coleambally Irrigation Co-operative Limited (CICL) recognises the importance of protecting the privacy of the personal information it collects. CICL respects individual rights to privacy under the Privacy Act 1988 (Cth) (the Act) and is required to comply with the Australian Privacy Principles (2014).
This Privacy Policy describes how CICL collects, uses, discloses and manages personal information.
The Information Security Policy is designed to protect CICL’s corporate data, confidential information, user safety, and privacy, and is used to guide CICL’s management and operational standards to ensure that the availability, confidentiality and integrity of business information is maintained.
The Privacy Policy also applies to Coleambally Irrigation Mutual Co-operative Limited (CIMCL), Aquilex and WaterMart™.
2. Personal Information
This policy assumes ‘personal information’ has the meaning given in the Act which in summary is as follows:
‘information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.’
3. Collection of personal information
CICL collects or holds information about individuals which includes staff, directors, members and customers which is essential to the operation of its business which includes but is not limited to:
provision of water delivery services and drainage services to its members and customers
management and operation of irrigation works and assets and infrastructure for the supply of water
the operation of its registers for land, water and delivery entitlements
administration of its entitlements contract with members and customers
the operation of WaterMart™
the facilitation of payment of Government funding to members and customers
provision of agricultural services as the Board may determine.
CICL also collects the personal information of contractors and consultants as part of its routine business operations.
Individuals have the right to anonymity or can provide a pseudonym when contacting CICL, unless it is impracticable or identification is a legal requirement.
The personal information CICL may collect and hold includes, but is not limited to:
Name, date of birth and contact details
Trading name and or company details including ACNs
Business and financial data include ABNs
Bank account and credit card details
Details of security interests in members’ contractual rights
Landholding information including land titles, area, LWMP related projects (i.e. EM-31, whole farm plans), soil types, groundwater information including groundwater levels, water use and crop types
Details of Waterways (Rubicon water ordering system) login information
Details of annual allocation trading, entitlement transactions and transformations
Water entitlement and delivery entitlement numbers held in the Members’ register
Details of a member’s shares held
Details of property transactions
Records of correspondence and meetings with individuals which may include unsolicited personal information
Curriculum Vitae, qualifications and licences relevant to employment or employment applications
Tender information and details of contractors and their employees, including insurance cover.
CICL may also collect personal information from Government agencies or departments and title search agents, where it is required to provide services to individuals.
CICL is required to collect certain personal information under laws including but not limited to the following:
The Water Act 2007 (Cth) and associated legislative instruments which requires disclosure of data to the Bureau of Meteorology
The Australian Competition and Consumer Commission’s information requestions under the Water Act 2007 (Cth) and the Competition and Consumer Affairs Act 2010 (Cth)
The Water Management Act 2000 (NSW) including CICL’s Combined Water Supply Work Approval and Water Use Approval, issued under the Water Management Act 2000
CICL’s Environment Protection Licence under the Protection of the Environment Operations Act 1997 (NSW)
The Co-operatives Act 1992 (NSW)
Co-operatives National Law
4. Purpose of collecting, holding, use or disclosure of personal information
Key reasons why CICL collects, holds, uses and discloses personal information include:
To communicate with the individuals
To allow CICL to supply its business services to its members and customers
To allow CICL to deliver government funding programs to its members and other programs/activities which members and customers may be involved in
To provide members and customers with access to protected areas of websites
To provide members and customers with information about its products and services
To allow account management, including billing and payment processing
For business planning which may include data analysis, policy development, marketing and research and development
To comply with any legislative requirements or conditions on CICL’s licences.
5. Access to and correction of personal information
Any individual whose personal information is held by CICL may request access to that information by contacting CICL via email, telephone, in person or in writing. CICL reserves the right to verify the identification of individual(s) requesting information. CICL will endeavour to provide individuals with information they are entitled to by a suitable method (for example by emailing, mailing or personal inspection). Where CICL is not required to provide the personal information CICL will provide the reasons why. No fee will apply to a request for personal information; however CICL reserves the right to charge a fee to recover the costs of retrieving the personal information in accordance with CICL Rule 133 (Notices).
Personal information can be updated or corrected by contacting CICL at the contact details below.
Members and Customers can correct their contact information by completing the Customer Communication Form.
6. Disclosure of personal information (including to overseas recipients)
CICL may disclose personal information:
To its representatives, contractors or third party service providers engaged by CICL to provides services, including computer/software hosting, infrastructure/works, consultancy, billing, financing, data collection and research and development
To meet its licence and compliance obligations including reporting and registration
To prospective Board members but only in connection to Board elections
With the consent of an individual or their legal representatives on the individual’s behalf
Where required or authorised by the law.
CICL stores personal information in electronic form using cloud-based services. This may include the storage of personal information overseas.
7. Storage and security
Personal information collected is stored in a range of ways, including on CICL information technology systems and databases or in paper based files.
CICL’s Information Security Policy is designed to protect information from misuse, interference or loss and also from unauthorised access, modification or disclosure. Part of the Information Security Policy is a Security Incident Response Plan (SIRP) that includes measures to minimise damage caused by an information security incident.
8. Complaints and questions
To lodge complaints or questions about CICL’s Privacy Policy, or if an individual believes CICL has breached its Privacy Policy, the individual should contact the Company Secretary at the contact details below.
CICL will record all complaints. After receiving a complaint CICL will:
Appoint a staff member to investigate the complaint/issue
Request further information to improve its understanding of the complaint/issue if considered appropriate
Take appropriate corrective actions to resolve the compliant or rectify the issue
Write to the individual to communicate the action(s) taken.
CICL’s Rules 131 and 132 also provide for dispute resolution and the establishment of a dispute’s committee.
9. Changes
In the event CICL changes its Privacy Policy the updated policy will be available from CICL’s website www.colyirr.com.au.
10. Contacting CICL
For further information, please contact:
7 Brolga Place/PO Box 103
Coleambally NSW 2707
Phone 02 6954 4003
Facsimile 02 6954 4321
Email cosec@colyirr.com.au