Privacy policy
General policy statement
V/Line Corporation (V/Line) is committed to protecting the privacy of its customers.
V/Line will only collect, use, store and disclose “personal information” in accordance with the Information Privacy Principles set out in the Privacy and Data Protection Act 2014 (Vic) and “health information” in accordance with the Health Privacy Principles set out in the Health Records Act 2001 (Vic) (collectively, the Privacy Laws).
This policy provides information on how your personal information or health information is managed by V/Line. It also provides information to you about how you can obtain information about your personal information or health information held by V/Line, including how they are collected and managed in accordance with the Privacy Laws.
This policy applies to all V/Line employees when dealing with personal information or health information. When V/Line enters into a contract with a third party or third party organisation for the provision of goods or services relevant to its functions and activities, those persons and organisations will be required to manage all personal information and health information in accordance with the Privacy Laws, and may also have their own relevant privacy policies.
This policy may be varied by V/Line from time to time. It may also operate in conjunction with internal V/Line privacy policies, specific policies and/or collection notices developed by business units which may provide guidance on particular privacy management systems.
Types of information
Personal information
“Personal information” means information or an opinion (including information or an opinion forming part of a database or application), that is recorded in any form and whether true or not, about an individual whose identify is apparent, or can reasonably be ascertained, from the information or opinion, but does not include information of kind to which the Health Records Act 2001 applies.
Examples of personal information that V/Line may collect include:
- Your name
- Sex
- Date of birth
- Address
- Financial details
- Marital status
- Education and employment history.
Certain kinds of personal information are referred to in the Privacy Laws as “sensitive information”. Sensitive information is given extra protection under the Privacy Laws. This type of information 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, “personal information” refers collectively to personal information and sensitive information, unless otherwise noted.
Health information
“Health information” means information or an opinion that can be linked to an individual, whether living or dead, and includes information about their:
- Physical, mental, or psychological health
- Disability status
- Expressed wishes about the future provision of health services
- A health service that has been provided.
What is not personal information?
Information that is contained in publications or other documents that are generally publicly available is not considered personal information. Examples include information contained in newspapers, magazines, annual reports, publicly available website content, social media content available to the public or a group.
Collecting information
V/Line will only collect personal information or health information from you if it is necessary for the provision of its services; for recruitment purposes if you are applying for a position with V/Line; or for purposes associated with the carrying out of its functions, including compliance with regulatory requirements or other statutory obligations and ongoing assessment and improvement of its services. V/Line’s functions include the provision of public transport services, the operation and maintenance of rail infrastructure and rolling stock, developing and delivering projects associated with the regional rail network, and all associated infrastructure and activities. Reasons that V/Line may collect personal information or health information from you include where you:
- Book tickets to travel with V/Line
- Travel with V/Line, or attend at V/Line stations or platforms
- Are not travelling with a valid myki, or engage in conduct that breaches public transport legislation
- Register with V/Line for the purpose of receiving updates about services or details about special offers
- Wish to make a complaint or comment about V/Line services or its staff
- Apply for a position with V/Line
- Provide services to V/Line
- Make a request for access to documents under the Freedom of Information Act 1982
- Inform V/Line of any special assistance you require when utilising its services
- Register lost property.
V/Line will endeavour to collect personal information and health information directly from the person to whom it relates. However, in some cases, the information will be collected from third parties. These third parties may include PTV, for example, where customers wish to make a complaint or provide feedback to V/Line via the Public Transport Victoria (PTV) call centre V/Line may also collect personal information from social media.
Collection notices
V/Line will take all reasonable steps to provide you with a notice setting out:
- Why your personal or health information is being collected prior to it being collected (or as soon as practicable after)
- How the information will be used, and
- The consequences, if any, for not providing the information.
V/Line acknowledges that there will be circumstances where notification prior to collection is not practicable, including for example, in emergency situations on a train or platform when a person requires medical assistance, or other situations where a person wishes to make a complaint via the call centre or directly to a V/Line front line staff member. Whenever it is lawful or practicable, V/Line will provide people with the opportunity of remaining anonymous.
Use and disclosure of personal information and health information
V/Line will only use or disclose personal information or health information for the purpose for which it was collected, or where the person has consented to the information being used or disclosed for another specified use.
From time to time, V/Line may be required to use or disclose personal information or health information where authorised by or required under law, for example, when ordered by a Court or Tribunal, compelled by a regulatory body including but not limited to the Office of the National Rail Safety Regulator (ONRSR), Transport Accident Commission (TAC), or Work Safe Victoria (WorkSafe). V/Line may also use or disclose personal information or health information in circumstances where it reasonably believes that such use or disclosure is necessary to prevent or lessen a serious threat to an individual’s life, health, safety or welfare, or to prevent or lessen a serious threat to public health, public safety or public welfare.
V/Line may also disclose personal information to third parties in the following circumstances:
- To PTV) or its nominees to use in connection with PTV’s functions related to passenger transport, or in respect of requests under FOI legislation that are better processed by PTV
- To the Department of Transport and Planning (DTP) in relation to enforcement of ticketing offences and other public transport offences, or in respect of requests under FOI legislation
- To other public transport operators and public transport authorities where a person has raised an issue or query that requires information from that operator or authority, but only to the extent that use or disclosure of the personal information is necessary to resolve the issue or query
- To specific contractors associated with performing services for V/Line, including for example in relation to coach services
- To investigators that may be retained by V/Line from time to time to investigate complaints about personal injuries or alleged damage to property
- To confirm the educational qualifications and criminal history of applicants for positions with V/Line
- To members of Victoria Police who are authorised to seek access to personal information for law enforcement purposes.
Where V/Line believes that use or disclosure of personal information to third parties is reasonably necessary, V/Line will require those third parties to have appropriate processes in place to comply with the Privacy Laws and protect the disclosed personal information.
V/Line may also use personal information for the purposes of investigating complaints made about V/Line staff. If a person requests to remain anonymous, V/Line will take all reasonable steps to avoid providing information in an internal investigation that may identify them. Where V/Line considers that use or disclosure of personal information is reasonably necessary to prevent or lessen a serious risk to an individual's health, safety or welfare or the health, safety or welfare of the public, and it considers that it cannot do so without disclosing an individual’s personal information, it may not be possible to maintain the requested anonymity. It might also not be possible for V/Line to investigate a complaint if a person does not consent to the use or disclosure of their personal information. V/Line will take all reasonable measures to ensure a person is informed of this requirement prior to the use or disclosure of their personal information.
V/Line may also use personal information to make contact with a person to follow up on a complaint or comment they have made about V/Line services, or to survey them to obtain feedback about improving those services.
Data security and destruction
Irrespective of whether your personal information or health information is stored electronically or in hard copy form, V/Line will take all reasonable steps to protect it from loss, unauthorised use or access, modification or unauthorised disclosure.
V/Line will also take all reasonable steps to destroy or permanently de-identify personal information or health information if it is no longer needed for the purposes for which it was collected, unless it is required to be kept in accordance with legislation, including the Public Records Act 1973 (Vic).
Data quality, access and correction
V/Line will take all reasonable steps to ensure that personal information and health information that it has collected and stored is accurate, complete and up to date.
You are entitled to contact V/Line to request access to your personal information or health information and to seek correction of that if it is out of date or inaccurate. On occasions, V/Line may refuse to provide access to personal information or health information, for example, if your personal information also includes personal information of another party, or if V/Line considers that provision of the personal or health information might cause harm to the person requesting it. In this case, V/Line may direct you to make a formal request under the Freedom of Information Act 1982 (Vic).
If you wish to seek access to personal or health information held by V/Line, or to make a complaint about how V/Line has handled your personal or health information, you should contact V/Line’s Privacy Officer at:
V/Line Privacy Officer
GPO Box 5343, Melbourne, Victoria 3001
privacy@vline.com.au
If you have been refused access to your personal or health information and wish to make an application under the FOI Act, you should send the request and application fee to:
V/Line Freedom of Information Officer
GPO Box 5343, Melbourne, Victoria 3001
foi@vline.com.au
Personal information and V/Line’s website
V/Line will record basic information when you visit its website, such as the server address, domain name, pages visited, browser type and browser version. This information is not used to identify you.
The purpose of collecting this information is to enable statistical analysis of the usage of the V/Line website and to enable V/Line to provide a better service to those who use its website.
A “cookie” may be placed in the browser files of your computer when you access the V/Line website. These can be used to track use of the site. This does not identify you personally, and we are not able to access any files on your computer.
V/Line’s website contains links to other websites. If you use these links, please note that third parties operate these sites. V/Line is not responsible for the content of any external website and V/Line’s policies and procedures do not apply to third party websites.
‘V/Line’ Mobile App
V/Line collects basic information that will assist in providing the service. This may include locations, destination as well as cookies and any other information that will be required for the application to function.
V/Line may use the application to source and store information such as complaints or contact information for the purpose of allowing V/Line to address the concerns of the public. 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 V/Line’s 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 V/Line’s mobile application and its current operating system.
The purpose for collecting this information is to enable statistical analysis of the usage of our site and to enable V/Line to provide a better service to those who use its application.