For information on privacy matters relating to the myki ticketing system, please contact Public Transport Victoria.
KDR Victoria Pty Ltd (ABN 42 138 066 074) trading as Yarra Trams ("Yarra Trams" or "we", "us" or "our") respects the privacy of its passengers, customers and other individuals it interacts with. Yarra Trams handles your personal information and if applicable, sensitive information, in accordance with the Australian Privacy Principles and relevant provisions of the Privacy Act 1988 (Cth). As a company contracted by Public Transport Victoria, which is part of the Victorian Government, to provide passenger and other services on the Melbourne metropolitan tram network, we also comply with the Information Privacy Act 2000 (Vic). There are also other State and Commonwealth laws that Yarra Trams complies with in relation to transport services, surveillance and electronic communications we may have with you.
1. Your right to anonymity and pseudonymity
In many of your dealings with Yarra Trams, you may choose to remain anonymous or use a pseudonym. However, this may restrict our ability to effectively respond to your enquires and requests. We will need to know your identity if:
(a) it is impracticable for us to deal with you unless we can identify you; or
(b) we are required or authorised by an Australian law or court/tribunal order, to only deal with identified individuals. For example, pursuant to the Victorian Transport (Compliance and Miscellaneous) Act 1983 (Vic), an Authorised Officer can obtain your name, address and evidence of identification where they have reasonable grounds to believe an offence has occurred.
2. Kinds of personal information we usually collect and hold
Personal Information means any information or opinion (that may not be true) about an identified individual or an individual who is reasonably identifiable, whether the information is recorded in a material form or not. Examples of personal information include your name, address, phone number, email or certain social media details.
Sensitive information is a subset of personal information that is afforded a higher level of privacy protection under the privacy laws. It includes health information and personal information about an individual's racial or ethnic origin, political opinions, membership of a political, professional or trade association or trade union, religious or philosophical beliefs, sexual preferences or criminal record.
Other than during the recruitment process, after a collision or other accident or in activities aimed at improving services for certain individuals, Yarra Trams generally does not collect sensitive information unless we are required or permitted by law to do so (for example by law enforcement agencies) or by you providing us with your consent.
As the operator of the Melbourne metropolitan tram network, Yarra Trams routinely collects the following types of personal information:
- Name, contact details and other information submitted to or obtained by our customer service department or tram depots as part of customer complaints, feedback, lost and found, or other communications ("Customer Service information");
- Name, contact details, opinions and answers to questions or surveys, social media details as part of our marketing and competition activities ("Marketing Information");
- Name, date of birth, contact details, professional memberships, criminal record, tax file numbers, bank account details and other information as part of the employee or contractor or consultant recruitment ("Recruitment Information");
- Name, contact details, vehicle registration number, government related identifiers such as your licence number and other information of drivers and witnesses involved in collisions with or accidents in or around our trams ("Collision details");
- Name, address, myki card number, government related identifiers such as your drivers licence number and/or passport number and other passport details, CCTV or surveillance activities or other identifying information ("Infringement Information").
In addition, in the course of complying with legislation, responding to feedback and/or improving our customer services, Yarra Trams may collect sensitive information about an individual’s disability.
Some of the information we collect as described above may also be used for other purposes permitted by law.
3. How we collect personal information
Yarra Trams generally collects the kinds of personal information described above in the following ways:
(a) Customer Service Information - including when:
- you contact one of our tram depots directly and provide your personal information to our depot manager or other representative;
- you contact Public Transport Victoria's call centre and agree for your personal information to be provided to us as a public transport operator for the purpose of responding to your complaint or feedback;
- you communicate with our customer feedback division or our staff members via telephone, email or letter and provide your personal information;
- you send written correspondence to our head office or other location ;
- you post information on or directed to any of our social media platforms, including our Facebook page, Instagram, YouTube, LinkedIn or Twitter accounts;
- your authorised representative, a family member or other third party provides us with your personal information.
(b) Marketing Information - when you or your authorised representative enter a competition or promotion on our website, or answer questions and provide information to our corporate affairs, marketing or other departmental representatives.
(c) Recruitment Information - during the recruitment process when we receive applications from individuals or deal with contractors or consultants, and from third parties (eg, police background checks).
(d) Collision Information- when a collision occurs, information obtained by our drivers, other Yarra Trams’ employees, and/or the police.
(e) Infringement Information - when an infringement occurs, by Authorised Officers, drivers or other staff members.
4. Quality and security of the personal information we hold
Yarra Trams ensures that the personal information we collect, use and disclose is accurate, up-to-date, complete and relevant. To help us do this, we ask that you please notify us of any changes to your personal information. We will correct your personal information if we receive a correction request from you, or we are otherwise satisfied your personal information should be corrected.
We also protect your personal information and keep it secure. Personal information we collect is held in secure and restricted access systems located in Australia, with the exception of information collected via social media which is held on the servers of that network. Access to these systems or files is restricted to certain Yarra Trams employees who require access to properly perform their work functions.
We also take reasonable steps to protect and keep secure your personal information by:
- imposing access rights and restrictions;
- using confidentiality agreements;
- enforcing internal policies;
- utilising secured site facilities; and
- utilising computer generated security tools such as firewalls and data encryption.
We cannot however guarantee that data transmission to or from us over the internet will be totally secure.
Subject to legal requirements, when we no longer require your personal information for any permitted purposes, we take reasonable steps to either destroy or de-identify your personal information. For example, upon completing a marketing competition, all personal information is deleted from our files, with any relevant aggregated de-identified information retained for research and analysis purposes within our business if needed.
5. Purposes for which we collect, use and disclose personal information
Yarra Trams collects, holds, uses and discloses personal information for purposes that are reasonably necessary for our operations, activities and functions. These purposes include:
- to undertake customer service functions including answering enquiries and complaints and improving our operational and customer service functions;
- to promote our business, provide information to customers, users and the public;
- to undertake research and development activities aimed at better understanding and improving our operations and services;
- to provide report and other information to, or respond to enquiries from, government departments such as Public Transport Victoria, Transport Accident Commission, Victoria Police;
- to investigate and take action in relation to suspected serious unlawful activity or misconduct and to prepare for and engage in dispute resolution activity including those arising from, collisions, other accidents or infringements and to deal with drive and insurance agents;
- to protect the safety of our passengers, drivers and other employees and to enable us to respond to emergencies;
- to evaluate applications, make recommendations, and manage and administer the engagement of contractors and consultants;
- for enforcement related activities conducted by, or on behalf of, an enforcement body;
- as required or authorised by law; and
- for any other purpose for which your consent is obtained, such as website competitions.
6. Disclosing personal information overseas and to third parties
Any information shared with our overseas parent company, Keolis SA and its related body corporate entities, is generally de-identified and aggregated. However some contractor information and other limited personal information may be shared with our overseas parent company and other related body corporate entities in the course of our business operations and functions. These companies are principally located in France.
In the event that any personal information is disclosed to overseas recipients, Yarra Trams does so in accordance with its privacy obligations.
In the course of its business functions and activities, and where otherwise required or authorised by Australian law or court/tribunal order, Yarra Trams may disclose your personal information to third parties, including to:
- your authorised representatives;
- your insurance agents and representatives;
- Public Transport Victoria;
- Transport for Victoria;
- Transport Safety Victoria;
- Department of Economic Development, Jobs, Transport and Resources;
- Victoria Police;
- Debt collection agencies;
- Public Transport Ombudsman;
- Transport Accident Commission;
- Competition prize providers; and
- Other third parties to whom you have consented to collect your personal information.
7. Links to 3rd party sites
8. Accessing and correcting personal information
You may request access to personal information we hold about you. To do so, please contact our Privacy Officer - see details under Contact Us section below.
We will endeavour to respond to your request generally within 30 days. We will provide you with access to the information in the manner you have requested where possible. However, we will not provide access in circumstances where:
- access would have an unreasonable impact on the privacy of other individuals;
- the information relates to existing or anticipated legal proceedings with you;
- denying access is required or authorised by an Australian law or court/tribunal order;
- access may prejudice enforcement related activities conducted by, or on behalf of, an enforcement body; or
- other circumstances prescribed by law.
If we do refuse access, we will provide you with written notice of our refusal, explaining why we have made the decision to refuse access, and information on how you can make a complaint if you are not satisfied with our decision.
While we will not charge you for an access request, we may charge you for our reasonable costs in providing access (such as photocopying and postage). We will notify you of any applicable charges prior to processing your request.
You may ask us to correct the personal information we hold about you by contacting our Privacy Officer - see details under Contact Us section below. We will respond to your request generally within 30 days. We will take reasonable steps to correct the information if it is inaccurate, out-of date, incomplete, irrelevant or misleading having regard to the purpose for which we hold it. In some circumstances we may require further information from you to support your correction request. If we refuse your correction request, we will provide you with written notice of our refusal, explaining why we have made the decision to refuse to correct your information , and details on how you can make a complaint if you are not satisfied with our decision..
We may collect information through Cookies about our services that you use and how you use them, like when you visit our website. Cookies do not contain personal information because they do not reveal the identity of an individual, and you may set your browser in a manner so your computer does not accept Cookies.
10. Mobile applications
Any reviews, including usernames and account details, posted on Google Play, Apple App Store or similar application store, are hosted on the servers of that specific application store.
User data which helps us to improve the performance of a Yarra Trams mobile application is collected anonymously, with no data kept to identify a specific end user. Information that is retained, may include the model of mobile phone used to access a Yarra Trams mobile application and its current operating system.
11. Social media
Yarra Trams actively uses social media platforms including Facebook, Instagram, LinkedIn, Twitter and YouTube.
While all data is kept on the servers of the respective social networks, there may be times where Yarra Trams will contact a user and ask them to voluntarily provide contact details for reasons including but not limited to answering customer feedback and sending competition prizes.
From time-to-time Yarra Trams may choose to use other forms of social media. The above principles will apply to such other forms of social media.
12. Complaint handling procedure
To make a complaint about our handling of your personal information, please submit your complaint in writing to our Privacy Officer - see details under Contact Us section below. Your complaint must include sufficient details to enable us to respond and will be treated in confidence.
Once we have received your written complaint, we will investigate your complaint and provide you with a response within a reasonable time after receipt of your complaint. We may also contact you to discuss the issues and potential options to resolve your complaint.
If you are not satisfied with our response or proposed resolution, you may make a complaint to the relevant State or Commonwealth privacy office, whose contact details are listed below.
As a guide, if your privacy complaint relates to our management of your personal information in the course of carrying out passenger services on behalf of Public Transport Victoria, then you should direct your complaint to Office of the Commissioner for Privacy and Data Protection. If you are unsure, you may contact us or the Office of the Commissioner for Privacy and Data Protection who will assist in where to direct your complaint.
Office of the Commissioner for Privacy and Data Protection
PO Box 24274
Melbourne VIC 3001
Local call within Australia: 1300 006 842
From outside Australia: +61 3 8684 7580
Office of the Australian Information Commission - see the OAIC privacy complaints page for more information on the lodging your complaint.
13. Contact us
GPO Box 5231
MELBOURNE VIC 3001
Tel: (03) 96193200
Last updated September 2018