Privacy Policy

Published Date : 16/11/2021

This privacy policy gives you information on how we collect and process personal information of people who are not our own employees. This includes information collected directly from individuals (including, for example, through our smart devices and via our website www.westpower.co.nz) and indirectly from third parties in the course of undertaking our business activities such as:

• connecting customers to our network and providing products or services to our customers;
• managing, improving, developing and maintaining our network;
• working to ensure public safety;
• doing business with our contractors or suppliers or with energy retailers or other organisations we do business with;
• considering and processing job applications;
• dealing with questions or complaints from our customers or any member of the public; and
• interacting with individuals through our websites.

1. Who we are

Westpower Limited ("Westpower") is the owner and operator of the electricity distribution network on the West Coast of New Zealand's South Island.

Westpower is committed to protecting the privacy of individuals.

References to "us", "our" and "we" in this policy refer to Westpower.

The address for Westpower is:

146 Tainui Street

PO Box 375

Greymouth

7805

Changes to the Privacy Policy

We keep our privacy policy under regular review and will provide notice of changes to this privacy policy on our websites. Those changes will be effective from the date they are posted.

2. What we do

Our business is to provide a secure supply of electricity to consumers throughout the West Coast.

3. The information we collect

Personal information means any information about an individual that allows an individual to be identified. We collect the following types of personal information about people outside our organisation:

• Our customers, landowners, and occupants of properties connected to our network:
  • Identity information: including first name, last name, company name and username or similar identifier;
  • Contact information: including billing address, delivery address, land title information and email address and telephone numbers;
  • Financial information: including bank account and payment card details.
  • Transaction information: including details about payments to and from such people and, other details of services and products they have purchased from us and our communications with you regarding those services and products;
  • Power usage information: including power usage at our customers’ properties, power produced, technical information about Distributed Energy Resource (DER) installed on our customers’ properties, and network issues at our customers' properties and the information collected about network connections, such as through our smart network devices;
  • Information about our customers' experiences received from our customers;
  • Insurance information: and
  • Vulnerable persons information: including if there is a person at a property who is medically or otherwise dependent on electricity supply.
• Our suppliers and other businesses with whom we have a business relationship:
  • Identity information and contact information; o Profile information; o Competencies and qualifications of staff of these obligations;
  • Safety systems and hazard management;
  • Quality and environmental control; o Information about plant and equipment, and insurance;
  • Staff wellness;
  • Passwords and logins that are provided by us.
• Job Applicants: Names, contact details and other personal information we receive in the course of processing your application (including from your referees and regarding your qualifications and experience).
• Members of the public, including people who interact with us over the phone and through our websites:
  • Technical information: including network location, internet protocol (IP) address, login data, browser type, referring domains, traffic channels, and version, time zone setting and location (city, country, latitude and longitude), browser plug-in types and versions, operating system, console logs, and platform, and other technology on the devices used to access this website.
  • Website usage information: including information about how you use our website including time of visit, pages visited, clicks on page elements, scrolls, inputs time spent on each page, other websites and apps users have in their browsing history if the user has this enabled in their Google account.
  • Marketing and communications information: including your preferences in receiving marketing from us and third parties and your communication preferences.
  • Closed circuit TV footage at our sites. o Information you provide us about yourself (including identity and contact information) when you contact us, including with a query or complaint.

You can choose not to provide your personal information to us, but that may impact on our ability to provide services to you and/or the functionality of our websites.

4. How we collect information

We use different methods to collect personal information from and about you. We'll often receive information directly from you:

• You may give us your personal information directly, including (for example) by filling in forms, completing customer surveys or by corresponding with us by post, phone, email or via use of our smart network devices or reception (including where you are a member of the public making a request, enquiry or complaint to us).
• You may give us your personal information when you make a job application.
• You may also give us your personal information when you interact with our websites. We will automatically collect information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see section 4 below for further details about how we use cookies.
• If you have a smart network device installed at your property, this will record data about your connection and usage.
• Through closed circuit TV surveillance devices at our sites.

However, we may also collect personal information about you where you have authorised this, this is permitted by law, or where the information is publicly available. This may include information from:

• Your electricity retailer such as consumption information, as well as contact name and address for your installation so that we can process discounts, and establish eligibility for participating in West Coast Electric Power Trust elections;
• Electricity Authority such as information and verification relating to ICP numbers.
• Call Care who respond to Westpower phone calls. They will collect information about you provided on a call and provide it to us to respond to your question or complaint.
• Surveyors, Council and other contractors who provide us with information relevant to your connection.
• Google Analytics who provide information relating to user behaviour, referrals, device information, network location, IP address, page usage, user demographics and interests and other websites and apps users have in their browsing history if the user has this enabled in their Google account (Third-party cookie tracking via Google Remarketing).
• Lucky Orange who provide information relating to location, referrals, IP address, data recording, visit number, custom data, behaviour tags, URLs viewed, DOM Tree, DOM Mutations, page interactions, linked CSS stylesheets and resources, console logs, and images.

If you have provided us with personal information about another person, you must have that person’s permission to do so.

5. How we use information

We will only use your personal information for purposes connected with our business which include using personal information to:

• interact and communicate with our suppliers and contractors with whom we do business;
• process and evaluate job applications and communicate with applicants;
• provide our customers with services and products (including connecting them to our network and interacting or communicating with our customers about our network and the services and products we provide to them) and to bill them for those services and products;
• manage, improve, develop and maintain our network (including quality improvement, public safety, ripple control and monitoring usage to gain understanding about requirements and performance and to optimise network performance) and ensure public safety;
• verify your identity and any information you provide to us (including your ICP number(s)) if required; • comply with our legal, regulatory, tax, insurance and/or accounting requirements;
• fulfil our purposes under the Electricity Industry Act 2010 and Energy Companies Act 2002;
• continually improve our website and the services and products that we provide;
• respond to planned and unplanned outages;
• carry out marketing and product analysis; and
• manage our relationship with you, including exercising or enforcing our rights.

We may also use your personal information for other purposes for which you have given permission or which is allowed or required by law.

We may use CCTV footage, if required, for detecting and deterring inappropriate or criminal behaviour at our premises, and monitoring the safety and security of our staff, visitors and property.

We may use your personal information to analyse trends, see patterns in our customers’ use of our network and for statistical purposes such as demographics to help us improve our customer service, manage our network capability and meet our legal obligations. However, wherever practical, your information used in this way will be aggregated with that of other customers, so you are not personally identified.

For the purposes set out above, we may disclose personal information to:

• our staff, our advisors and our service providers and suppliers where necessary for us to be able to use personal information for the purposes set out above; and
• anyone who we need to share information with by reason of law or regulation or to address any complaints you make to a third party or regulator (such as the Privacy Commissioner);
• with a court, tribunal or authority in the course of proceedings or investigations;
• anyone who you authorise us to share information with.

We may also disclose information to potential purchasers of our business.

Cookies

We may use cookies and other interactive techniques such as web beacons to collect information about how you use our website to:

• provide you with a more enjoyable, customised service and experience on our website; • enable you to use certain services on our website;
• help us develop and deliver better services and products which are customised to our customers' interests; and
• help us manage security and fraud risks.

We may also use persistent cookies so that you can set your preferences for using our website (for example, to remember your log in details).

You can usually set the settings on your browser to let you know when you are offered cookies so that you can decide whether or not to accept them. However, if you disable or refuse cookies, please be aware that some parts of this website may not function properly

6. Security

We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date.

We may store your personal information on computer databases and/or in hard copy. We take reasonable steps to ensure your personal information is stored securely and protected from unauthorised access, modification or disclosure and misuse or loss. However, due to the nature of email and the internet, we cannot guarantee your personal information will be completely free from access by an unauthorised person. However, we use reasonable safeguards to minimise the risk of this occurring.

We may store your personal information using a third-party service provider (including providers outside New Zealand). We take steps to ensure that, where your information is disclosed outside NZ, it remains subject to safeguards that are comparable to those contained in NZ's Privacy Act.

We have procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where required by law.

7. How long we keep information for

We will only retain your personal information for as long as we believe is reasonably necessary. We will de-identify and aggregate information wherever possible. We take all reasonable steps to ensure that your personal information is securely destroyed or deleted, once it is no longer needed for the purposes we collected it. We may be required by law to retain certain personal information.

8. Your rights

You have rights to see and request the correction of any personal information we hold about you. If you want to exercise these rights or to ask us questions about this privacy policy, please contact us using the Contact Us form on our website, or at the below email address or phone number:

Westpower Limited

Email address: info@westpower.co.nz

Telephone number: 03 768 9300

There may be charges associated with providing copies of your personal information to you. We will always advise you of those charges in advance.

We may require you to contact your electricity retailer if we received the incorrect personal information from them, in order to achieve a permanent correction.

This privacy policy is governed by New Zealand law. For more information about privacy issues in New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner's website at www.privacy.org.nz