Public Transport Victoria (PTV) will collect, use, store and disclose Personal Information and Health Information in accordance with the Information Privacy Principles (IPPs) set out in the Privacy and Data Protection Act 2014 (Vic) (Privacy and Data Protection Act) and the Health Privacy Principles (HPPs) set out in the Health Records Act 2001 (Vic) (Health Records Act).
This policy is designed to assist people to understand how their Personal Information and Health Information is managed by PTV.
Information is also provided about how people can seek assurance that their Personal Information and/or Health Information is maintained in accordance with the Privacy and Data Protection Act and the Health Records Act.
This policy applies to all employees of PTV when dealing with Personal Information or Health Information. Where PTV enters into a contract with another organisation for the provision of goods or services relevant to the functions and powers of PTV, those organisations will be required to manage all Personal Information and Health Information in accordance with the Privacy and Data Protection Act and the Health Records Act too, but may have their own relevant privacy policies.
This policy may be varied from time to time and will operate consistently and in conjunction with customised privacy policies and collection statements developed by individual business or work units within PTV to explain their particular privacy management practices.
Types of Information
'Personal information' means information or opinion about an individual whose identity is apparent, or can reasonably be ascertained, from that information or opinion. Some examples of Personal Information are your name, sex, date of birth, address, financial details, marital status, education and employment history. Some Personal Information is called 'Sensitive Information' and is given extra protection under the law. This includes information about an individual’s racial or ethnic origin, religious beliefs, political views, sexual preferences, membership of unions and criminal record.
In this policy, the term 'Personal Information' will refer collectively to Personal Information and Sensitive Information, unless otherwise specified.
'Health information' means information or an opinion that can be linked to an individual, whether living or deceased, that is about their physical, mental or psychological health, disability status, expressed wishes about the future provision of health services to him or her, a health service that has been provided, or a health service that will be provided.
What is not Personal Information?
Information contained in publications which are generally available is not Personal Information. Publications which are generally available include magazines, books, newspaper articles, annual reports and the Victorian Government Gazette.
PTV will only collect Personal Information or Health Information from an individual if it is necessary for the provision of services to that individual, or to carry out PTV’s functions. PTV will always take reasonable steps to collect Personal Information or Health Information directly from the individual the information concerns.
PTV’s principal functions are to plan, coordinate and provide public transport services across Victoria.
Reasons that PTV may collect Personal Information or Health Information from a person include if they:
- are employed by, or apply to be employed by, PTV;
- request to be placed on a mailing list maintained by PTV;
- contact PTV directly, or contact the Victorian Government about a matter relevant to PTV’s function or services;
- are provided with products or services by PTV; or
- make a request for access to documents under the Freedom of Information Act 1982 (Vic) (Freedom of Information Act).
Collection statements / notices
At or before the time PTV collects any Personal Information or Health Information from a person (or if that is not practicable, as soon as practicable afterwards), PTV will take reasonable steps to ensure that they are given a collection statement setting out the purpose for collecting the information, how the information will be used and the consequences, if any, for not providing the information requested.
Whenever it is lawful and practical, PTV will provide people with the option of not identifying themselves.
Examples of information which may be collected, used, stored or disclosed by PTV
Correspondence (including emails) or complaints addressed to Victorian Government Ministers or agencies, or queries made through PTV’s call centre or PTV Hubs regarding matters related to the functions of, or service provided by, PTV may be referred to PTV for advice and response. Such correspondence, as well as correspondence addressed directly to PTV, may include Personal Information or Health Information, and may be accessed by PTV staff, subject to operational need.
Copies of correspondence, applicable responses and details pertaining to correspondence received by PTV which contain Personal Information or Health Information may be retained by PTV for certain periods of time, in accordance with the Public Records Act 1973 (Vic) (Public Records Act) and other applicable legislation.
Information collected on PTV’s website and smart device applications
Unless information is expressly provided to PTV by a visitor to PTV’s website or smart device apps, PTV will not know the identity of any visitor to its website or apps.
Cookies used by ptv.vic.gov.au are enabled by default because of their integration into the website. If you do not wish to have cookies placed on your computer, you can disable them using your web browser. You will need to customise each web browser you use to turn off cookie tracking. Cookies are not used by PTV’s apps.
Visitors to PTV’s website and smart device apps will be subject to PTV’s standard web logs, which record anonymous information about traffic patterns through PTV’s website and apps for statistical purposes only. No attempt will be made by PTV to identify the personal details of any visitor, except in the event that an investigation is undertaken by a law enforcement agency, exercising a warrant to inspect PTV’s standard web logs.
This site also uses ClickTale web analytics service. You can choose to disable the Service via the Clicktale website. We use this anonymous information for statistical purposes and to ensure our website is providing relevant information.
Visitors to PTV's website who have arrived by clicking on a banner advertisement may have their activity tracked by a web beacon. Web beacons allow us to measure the effectiveness of our internet information campaigns. Web beacons don't track activity if you have cookies disabled in your browser.
We may use local device storage to store information on your computer. We use local storage to help remember your favourites, recent history and past searches. If you don't want to use local storage, your browser may be able to disable it. However, if you disable local storage, some parts of the website might not function correctly.
When you use PTV’s smart device apps, they may collect certain information automatically, such as the type of device you are using, the device ID, IP address and IMEI number. Where possible, unique identifiers are anonymised and at no time will PTV attempt to identify you as an individual (unique identifiers are discussed further below).
PTV uses this data to improve the usability and efficiency of PTV’s website and apps. PTV will not use Google Analytics to track, collect or upload any data that personally identifies an individual, or other data that can be reasonably linked to such information by Google. See further information about how Google Analytics collects and processes data.
Employment and recruitment information
If a person is employed by, or applies to be employed by, PTV, PTV may collect and store information about the recruitment process used and their application including character checks, security clearances and criminal history checks undertaken as part of that process.
Employment and recruitment information collected by PTV may be retained for certain periods of time, in accordance with the Public Records Act, the Public Administration Act 2004 (Vic) and other applicable legislation. Some of this information may be disclosed to third parties, where legally required.
For more information, see the Public Transport Victoria Recruitment Privacy Statement.
Use and disclosure of information
PTV will only use or disclose Personal Information or Health Information for the purpose which was either specified or reasonably apparent at the time of collection, unless the individual in question has consented to the information being put to another related use, or would reasonably expect that the information would be put to another related use.
PTV will only use Personal Information or Health Information for another purpose if the secondary purpose directly relates to the primary purpose for which it was collected. In some circumstances, PTV may be authorised by legislation to use or provide Personal Information or Health Information to another organisation for a particular reason. For example, PTV may not have to comply with the IPPs when exercising responsibilities directly related to law enforcement or where the Australian Security and Intelligence Organisation (ASIO), the Australian Secret Intelligence Service (ASIS) or Centrelink have requested the disclosure of your Personal Information or Health Information.
PTV will only transfer your Personal Information or Health Information to another individual or organisation in limited circumstances, including that the recipient is subject to a law which upholds similar principles to the IPPs or HPPs, or if the transfer is consented to.
PTV may also provide your Personal Information or Health Information to public transport operators and public transport authorities (such as Transport Safety Victoria or the Department of Transport, Planning and Local Infrastructure) where you raise an issue or query with PTV and responding to that issue or query requires information from that party.
Data security and destruction
Irrespective of whether your Personal Information or Health Information is stored electronically or in hard copy form, PTV will take reasonable steps to protect it from misuse, loss, unauthorised access, modification or disclosure.
PTV will also take reasonable steps to destroy or permanently de-identify your Personal Information or Health Information if it is no longer needed for the purpose (or a related purpose) for which it was initially collected, unless, in the case of Personal Information, it is subject to the Public Records Act, in which case it will be retained or disposed of in accordance with that legislation.
Data quality, access and correction
PTV will take reasonable steps to ensure that Personal Information and Health Information it collects is accurate, complete and up to date.
People are entitled to contact PTV's Information Privacy Officer (contact details are set out below) and request access to, and correction of, any of their Personal Information or Health Information held by PTV. PTV will take reasonable steps to correct and update any Personal Information or Health Information that is established to be inaccurate, incomplete or not up to date or provide you with a written statement if such a request is refused.
If a person’s Personal Information or Health Information is associated with information relating to an event, commercial activities or in some way affects the privacy of another individual, they may need to make a formal Freedom of Information request pursuant to section 17 of the Freedom of Information Act. Your Freedom of Information application should be made to:
PTV Freedom of Information Officer
PO Box 4724
Melbourne VIC 3000
Telephone: 1800 800 007
Facsimile: 9027 4074
A unique identifier is a code consisting of letters or numbers (not the individual’s name) that is assigned to an individual to distinguish them from other individuals - for example a drivers licence number.
PTV will not:
- assign, use or disclose unique identifiers to individuals unless it is necessary to do so to carry out one of its organisational functions efficiently;
- adopt, use or disclose a unique identifier assigned to any person by another organisation except in limited circumstances; or
- require people to provide a unique identifier in order to obtain a service, unless it is required or authorised by law or connected to the purpose for which the unique identifier was assigned.
The following information refers to privacy and myki. Most cardholders may choose whether they want to register their myki. Find out the benefits of registering your myki.
Personal information will be collected if you choose to do any of the following things:
Registering a myki
Registration will require at least minimum contact details. For some concession cardholders, it is mandatory to register and personalise their card (with name, or name and photo), depending on the category of concession entitlement. Registered cardholders can choose to personalise their myki with their name if this is requested at the time of purchase.
Personal information provided by or about the account holder or cardholder, or generated by using the card, is collected by PTV to enable it to issue and administer the card and relevant entitlements. The account holder or cardholder will generally be able to access his/her personal information. PTV requires personal information to provide the card and related services, such as registration.
Setting auto top up
If you choose to register for auto top up (a direct debit facility from your credit card or bank account), PTV will need to hold relevant details required for payment processing.
Topping up by credit or debit card
If you choose to add value to your unregistered myki by using a credit or debit card, your credit card details are provided to PTV's bank and not retained by PTV.
Ordering an unregistered myki via the PTV website or PTV call centre
If you order an unregistered myki via the website or call centre, your contact details will be required temporarily to issue the myki. These details will be deleted about 30 days after the myki is mailed to you.
Making a query or complaint
PTV may require personal information (contact details) in order to respond to queries or complaints.
Use and disclosure
Use of the myki will generate a record, which will include the location, time and date of the transaction. If a cardholder has provided personal details, PTV will have the ability to link these with cardholder's transactions. However, PTV or its agents will not normally need to do so in connection with the operation of the payment system.
PTV and its agents will take all reasonable measures to secure personal information.
Accessing or correcting your information
To view or correct information that PTV holds about you, log into your account (if you have set up online access) to change your details directly or contact the call centre on 1800 800 007 6am – midnight daily.
If you believe that your Personal or Health Information has been used by PTV in a manner contrary to the Privacy and Data Protection Act or Health Records Act, you may contact PTV's Information Privacy Officer.
PTV Information Privacy Officer
PO Box 4724
Melbourne VIC 3000
Telephone: 1800 800 007
Facsimile: (03) 9027 4074
Complaints about any use of a person’s Health Information which is believed to be contrary to the Health Records Act can be made to the Health Services Commissioner. Information about submitting complaints in respect of Health Information is available at www.health.vic.gov.au/hsc.
Health Services Commissioner
570 Bourke Street
Melbourne VIC 3000
Telephone: 1300 582 113
Facsimile: (03) 9032 3111
People can also contact the Commissioner for Privacy and Data Protection for more information or to raise certain complaints about privacy matters and regulation in Victoria.
Privacy and Data Protection Victoria
Level 6, 121 Exhibition Street
Melbourne VIC 3000
GPO Box 24014
Melbourne VIC 3001
Telephone: 1300 666 444
Facsimile: 1300 666 445