PowerNet Limited (“PowerNet”) is a network management company responsible for managing the electricity networks of Electricity Invercargill Limited, The Power Company Limited, Electricity Southland Limited and Pylon Limited and Last Tango Limited as participants in the OtagoNet Joint Venture (together with PowerNet, the “PowerNet Group”).

This Privacy Policy governs the PowerNet Group’s (referred to in this Privacy Policy as “we”, “our” or “us”) collection, use and disclosure of your personal information and has been prepared in accordance with our obligations and your rights set out in the Privacy Act 2020.

Application

This Privacy Policy applies to any personal information we collect to allow us to deliver electricity services to you, and that we collect when you interact with us and any of our related companies and entities, including when you:

1. Use our website;
2. Visit any of our premises;
3. Communicate with us; and
4. Register to receive marketing communications or enter into a competition or promotion;

(together the “Services”)

In the event of any inconsistency between this Privacy Policy and other policies or terms and conditions that may apply to your use of any of the Services, the terms of this Privacy Policy will prevail.

Information we collect

The information we collect may include:

• your contact details including your name, postal address and telephone number;
• address of premises to which we deliver electricity services to you;
• if anyone at your address is reliant on medical equipment that requires a power supply;
• information about electricity that has been consumed or produced at your property including if applicable, your electricity load profile; and
• details of communications we have had with you.

When you use our website we may also collect information including the IP address of your device and the date and time you are visiting the pages you view.

How we collect information

Where possible, we collect information directly from you, for example, when you contact us by phone, email or via our website.

We may also record and store customer phone calls and camera footage from our reception areas.

Information may also be collected from other sources, such as:

• information relating to electricity consumption or production at your property, which we collect automatically from your smart meter;
• information about you which is provided to us from other organisations involved in the supply of electricity to you, for example, your electricity retailer or a registered electrical contractor or other relevant party who requests a service from us (e.g. to obtain a connection or supply of electricity to you);
• information about you from monitoring software or google analytics when you use our website.

How we use information we have collected

We use personal information that we collect:

• help us provide services to you and run our business more efficiently, for example: to manage, maintain and improve our electricity network;
• to deal with your requests, inquiries and complaints about our electricity networks;
• to set the correct tariff for electricity consumption at your property;
• to inform you about the electricity network, for example planned outages and scheduled maintenance; to carry out activities required by law or regulatory requirements;
• for specific purposes notified to you at the time of collection;
• to notify you of your obligations in respect of tree trimming around power lines;
• to enable the Southland Electric Power Supply Consumer Trust to liaise with the Trust beneficiaries to pay annual discounts, organise trustee elections and otherwise contact beneficiaries as required);
• for administration or business purposes;
• to provide you with information related to your use of the electricity network;
• to monitor safety and security of our staff and our sites;
• to ensure the safety and security of our staff and visitors to our buildings and work sites;
• with your consent, to provide you with information about any new services that may become available; and to improve our services to you;
• for contact tracing in relation to the Covid-19 pandemic.

When you access our websites, social media pages and/or mobile apps, we may use cookies where they are required for particular features to work – for example, if you are a logged in user, to allow you to remain logged in whilst you complete certain tasks. Some information/Services may be unavailable if you chose to disable your browser from accepting cookies. Cookies are small text files that are placed in your browser by the websites you visit. They are widely used to help users navigate websites efficiently, to perform certain functions on the sites, and/or to provide site owners with information about how their sites are used.

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics do not identify individual users or associate your IP address with any other data held by Google. We use Google Analytics to analyse the website traffic and webpage usage. By using our website you consent to the processing of data about you by Google in the manner described in “How Google uses data when you use our partners’ sites or apps” on Google’s website, this can be read at  www.google.com/policies/privacy/partners

Our website also uses Wordfence a security plugin service which provides us with various options to protect our site from malicious software such as firewalls.

Disclosing your information

We may share your personal information within the PowerNet Group our related companies and entities and where you provide personal information to any of member of the PowerNet Group our related companies and entities they may share that information with us or any of the other related companies or entities.

We may also share your personal information with:

• third parties including our agents, contractors and service providers so that they can provide services on our behalf, such as installing or maintaining your meter and resolving faults;
• your electricity retailer;
• anyone you have authorised us to disclose information to;
• credit reference agencies (unless we have agreed otherwise), who may share your information with other organisations and who may keep a record of the searches we make against your name; or
• anyone we transfer our business to in respect of which you are a customer or a potential customer;
• other parties, in order to comply with a legal or regulatory requirement or where we are permitted to do so by applicable law.

We may also share smart meter data with our partners, contractors and service providers for the purposes of managing and improving our electricity network.

By using any of our Services you consent to your personal information being disclosed to the entities and persons as described in this section. Other than as outlined above, we will not share your personal information with, or sell or license it to, any other third parties except as required by law or where disclosure is necessary to prevent a threat to health, security or safety.

However, as detailed in Google’s privacy policy Google may share information they have collected publicly and with their partners.

How we protect and store your information

We take all reasonable steps to ensure your personal information is stored in a secure environment. However, communications over the internet, such as emails are not secure, unless they have been encrypted. It is your responsibility to protect access to any emails you receive from us.

Accessing and updating your information

You can request access to any personal information we hold about you by contacting our Customer Experience Manager at comms@powernet.co.nz. We will comply with any request to access personal information we hold about you, where it can be readily retrieved, unless there is good reason (in accordance with the Privacy Act) for not doing so, including where such a disclosure would breach someone else’s rights to privacy and/or the law. There is no fee for making such a request, however, we may charge you a reasonable amount for providing copies of that information.

If we do not allow you to access your personal information, we will provide you with the reasons for our decision. If so, we will provide you with information concerning your right to seek an investigation and review of the refusal.

You can ask us to amend information we hold about you that you believe is not correct. We will update it if we think it is reasonable for us to do so. If we do not agree to your request, you can request us to take reasonable steps to attach a statement of the correction sought but not made to the relevant information.

Electronic marketing

Where you subscribe to receive emails from us, your name, contact details and address will be added to our database, and you consent to receiving messages from us by email, text message, or physical mail (depending the information you provide us and your stated preferences).

All commercial electronic messages you receive from us will contain a unsubscribe function. If you no longer want to receive commercial electronic messages from us you can unsubscribe from such commercial electronic messages by using the unsubscribe function or by contacting the specified PowerNet email address (if applicable). We will endeavour to update your preferences as soon as possible.

Data retention

Once your personal information is no longer required for our (lawful) purposes, we will destroy it in accordance with industry practice.

Complaints

You have the right to complain, if you feel that we have not responded to your request to solve a problem regarding your personal information. You can lodge a complaint direct to our Privacy Officer by emailing dstevens@powernet.co.nz

You have the right to lodge a complaint to the New Zealand Office of the Privacy Commissioner. Information on how to lodge a complaint is available on their website.

Changes to our privacy policy

We may make changes to this Privacy Policy from time to time. The updated policy will be available on our website and the changes will apply from the date the policy is posted on our website.

Dated: 10 November 2021