Privacy Policy

1. Purpose

Busways Group Pty Ltd (Busways) recognises the importance of the privacy of individuals who have dealings with Busways, such as customers, suppliers, contractors and employees. Busways is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Privacy and Personal Information Act 1998 (NSW), the Health Records and Information Protection Act 2002 (NSW), the South Australian Government Information Privacy Principles, and any other legislation which regulates the collection, use and disclosure of information and opinions about identified or identifiable individual (personal information).

This policy outlines how Busways collects, uses and manages personal information, and outlines how you can contact Busways if you wish to access your personal information, inform Busways of a change to any personal information Busways holds about you, or submit a complaint about Busways’ management of your personal information.

2. Personal information Busways collects

Busways collects personal information where reasonably necessary for its functions and activities.

Personal information that Busways may hold about its customers includes the following:

  • name, address and contact details if make a booking or provide us with feedback;
  • date of birth of a customer when the customer or their guardian applies directly to Busways for a student pass;
  • details of the products and services provided to an individual by Busways;
  • details of a booking, including your pick up location and time, drop off location, accessibility requirements, cost;
  • details of an individual’s dealings with Busways, including records of telephone, email and online interactions;
  • records of journeys with Busways where you have booked an on-demand or chartered service;
  • information relating to an incident or complaint involving you;
  • your image on CCTV which we operate at our bus depots and on our buses.

We do not collect any personal information from you when you use the Opal (NSW), Metro Ticketing System (SA), or any other relevant State public transport ticketing systems. That information is directly collected by the relevant State Department (e.g. Transport for NSW or Department of Infrastructure and Transport SA).

If you are applying for a job with us, we may collect your:

  • name, address and contact details;
  • date of birth;
  • prior employment details;
  • references;
  • qualification confirmation;
  • medical and health details contained in a pre-employment medical review;
  • working with children driver authority (NSW) / driver accreditation (SA);
  • photographs taken when signing in at Busways sites;
  • images on CCTV footage taken at the bus depot, around offices and on buses.

If you are applying to become, or are, a supplier or contractor to Busways, we may collect the following information:

  • contact details including supplier email and phone number;
  • bank account details for payment of invoices.
3. Dealing with us anonymously or using a pseudonym

Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately respond to your question. You can also make complaints anonymously, if preferred.

4. How Busways collects personal information

Busways collects personal information directly from an individual where reasonable and practical. Busways may also collect such information from other sources, including:

  • CCTV systems in use in buses, at bus depots and around offices;
  • State Departments (e.g. Transport NSW or Department of Infrastructure and Transport SA) where there is feedback or a complaint made about our public transport service;
  • other entities who provide services to or jointly with Busways related to the products and services provided to an individual by Busways;
  • publicly available sources of information;
  • an individual’s authorised representative if the relevant person doesn't have capacity; and
  • subsidiaries of Busways.
5. Why Busways collects and uses personal information

Busways collects and uses your personal information for the following purposes:

  • to lawfully carry out Busways’ functions and activities, which include providing public bus services;
  • to deliver services to you that you requested;
  • to provide you with further information about any services you requested;
  • to personalize and customise your experience with Busways;
  • to assist Busways review, manage and enhance its services;
  • to communicate with you, including by email, telephone and post;
  • for administrative purposes, such as charging and billing;
  • to promote and market those of our services that we consider may be of interest to you;
  • to provide you with news about any of Busways' services;
  • to undertake customer surveys;
  • to consider making offers to job applicants and prospective employees or for other employment purposes;
  • to manage and enhance your experience on our website;
  • to improve security at the bus depot and on buses;
  • to manage incidents or complaints;
  • to investigate where we have reason to suspect you have breached any relevant terms and conditions of our services;
  • to receive services from you or the organization that employs you; and
  • as otherwise required or permitted by law.
6. Disclosure of personal information

Busways understands the importance of keeping personal information private and only discloses personal information to third parties in limited circumstances. Third parties with whom Busways usually exchanges information include:

  • State Departments (e.g. Transport NSW or Department of Infrastructure and Transport SA) as required by our contract to provide public bus services, including details of bookings, customer feedback, and incidents;
  • an individual’s authorised representatives;
  • Busways’ professional advisers including legal, accounting, auditing and business consulting advisers;
  • government agencies, and regulatory bodies and law enforcement agencies or other similar entities;
  • anyone to whom part of or all of our assets or businesses are sold or transferred;
  • subsidiaries of Busways; and
  • any other parties that Busways is required or permitted by any relevant law to disclose personal information to in the circumstances.

Busways also exchanges personal information with contractors who manage services provided to an individual on Busways’ behalf, or who provide services to Busways, including:

  • mailing services;
  • billing and debt recovery functions;
  • customer injury services;
  • marketing functions; and
  • website, data management and technology services.
7. Website usage information and cookies

When you use our website, Busways collects certain standard information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses. Busways also uses Google Analytics to collect this information about your interaction with Busways’ websites. For more about how Google collects and processes data, and your privacy choices with Google, please check Google’s privacy policy for more information.

Busways uses this information to administer its website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Busways also collects certain information to provide users with a personalised experience when visiting Busways’ websites. 

Through the use of a ‘cookie(s)’, Busways can record information about your visit to Busways website including the clickstream to, through and from Busways’ site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used in aggregated form only, and is collected and logged for statistical purposes. Through analysis of these
records, Busways is able to provide an improved service when users revisit Busways’ websites.

A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and your preferences. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data from your hard disk or read cookie files created by other websites.

Busways uses cookies to track user traffic patterns and to provide a better service for users when they visit the website. Users can set their browsers to provide notification when a cookie is received, and the opportunity to accept or reject the cookie. Users can also refuse all  cookies by turning the function off in their browsers, although this may affect your browsing experience.

8. How Busways stores personal information

Busways stores personal information at its own premises and with the assistance of its service providers in hard copy and electronically. Busways maintains strict procedures and standards and takes all reasonable and appropriate steps (including organisational and technological measures) to prevent unauthorised access to, or disclosure of, personal information and protect an individual’s information
from misuse or loss.

Busways only keeps your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. Once an individual’s information is no longer needed by Busways, reasonable steps are taken to destroy or de-identify it. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

9. Accessing and updating personal information

Busways will endeavour to ensure that personal information collected from you is up to date, accurate and complete.

In most cases an individual can gain access to or update personal information held by Busways.

To make a request to access or update personal information held by Busways, contact Busways Privacy Officer in writing using the contact details provided within Section 10 below. Busways may need to verify your identity before responding to your request. Busways will respond to your request within a reasonable period of time (and for health information in NSW, within 45 days or if 45 days has passed and Busways has specified that a fee is payable, within 7 days or receiving payment of that fee). If Busways decides to refuse your request, we will tell you why in writing and how to complain. Busways may charge a fee to cover the cost of retrieving and copying requested information.

10. Complaints and further information

Further information may be obtained about how Busways manages personal information from the Privacy Officer (see contact details below). If an individual believes that Busways has breached its privacy obligations (including any breach of the Australian Privacy Principles) or that individual’s privacy rights in any way, a complaint can be made to the Privacy Officer (see contact details below). Busways will endeavour to respond to you within a reasonable period of time to acknowledge your complaint and inform you of next steps.

If you are not satisfied with Busways' response, you may complain to the Office of the Australian Information commission (OAIC) via the OAIC website, www.oaic.gov.au

Busways Privacy Officer
Locked Bag 1015, Gordon NSW 2072
hrhelpdesk@busways.com.au

11. Employee information

Where Busways collects personal information pertaining to a current or former employee, Busways will only use or disclose the information for purposes directly related to the employment relationship.

Employees can access and update or correct their personal information in accordance with the process in section 9 above and can raise any complaints about the handling of their information in accordance with section 10 above.

12. Additional Information

For further information or to discuss any questions in regard to this policy and its application, Busways employees should contact the Human Resources team via the HR helpdesk.

12.1 Review
This document and the effectiveness of its implementation, including all associated forms and documents will be reviewed every 24 months.