(Including Credit Reporting Policy)
Effective Date: 20 July 2020
1. About us
Southern Phone Company Limited (Southern Phone) provides telecommunications goods and services, including broadband internet, mobile and home phone services, and other related products and services.
This policy describes how Southern Phone handles your personal information and credit-related information. You can find out more about Southern Phone on our website.
Southern Phone is a member of the AGL Group. For information about how other AGL Group members handle personal information and credit-related information, see the AGL website. In this policy, AGL Group means AGL Energy Limited and its related companies.
2. Your privacy is important to us
We keep your information safe. We aim to be clear and open about what we do with it.
We understand that your privacy is important to you, and we value your trust. That’s why we protect your information and aim to be clear and open about what we do with it.
Personal information has the meaning given in the Privacy Act 1988 (Cth) (Privacy Act), which includes information that identifies you or can be reasonably linked to your identity.
Credit-related information is information about how you manage your credit, the credit that you have applied for or obtained, your payment history and creditworthiness and the information contained in your credit file.
When we collect this information, we follow the obligations set out in the Privacy Act and Privacy (Credit Reporting) Code 2014.
3. What information do we collect?
We collect information about you when you interact with us. We may also collect information about you from other people and organisations, including other AGL Group members.
We only collect your personal information when we or other AGL Group members need it to provide our products and services or to comply with the law. The kinds of information that we collect depends on how you interact with us. Here are some examples.
Information we collect from you
We collect the name and contact details (landline, mobile, email) of our customers and their authorised representatives as well as customers of other AGL Group members, shareholders, business contacts, job applicants and contractors and others. We may also collect:
• If you are a customer: Your date of birth, address (supply and mailing if different), address history (where relevant), concession details (where applicable), other forms of identification (such as driver’s licence or passport), payment details, ABN (if applicable) and information about your use of our products and services including phone and broadband usage, such as the time and duration of your communications.
• If you are an authorised representative on another person’s account: First name, last name, date of birth, telephone number, address and the relationship with our customer.
• If you apply for a job with us: Information that you provide about your right to work, employment history, qualifications and ability.
We collect information when you interact with us using the channels we make available to you – online, through our app, direct contact with our contact centre, social media, and using any voice tools (eg Amazon Alexa and Google Home).
If you give us personal information about other people, we will assume that they have agreed that you can do this.
Information we collect from others
• When you sign up with us: Your credit history information.
• We collect credit-related information from credit reporting bodies about you when you set up an account with us or when your account is in default. This information can be found on your credit file, including the fact that you have applied for credit, the amount and type of credit, details of your current and previous credit providers, start and end dates of credit arrangements, and information about listings on your credit file including defaults and court judgments.
• We collect credit-related information from other AGL Group members (where permitted by law), from public sources, and from other third parties including government agencies such as the Australian Financial Security Authority which manages the National Personal Insolvency Index.
• When you use our websites, mobile apps and platforms: Your IP address, device identifiers and information about how you use our websites, mobile apps or platforms such as session information and login attempts. We use web analytics services to do this. These services may include: Google Analytics, Google AdSense, DoubleClick, Adobe or Microsoft.
• When you participate in market research: Information about you and your responses from the service provider that conducted the research.
• When you engage with our sales partners, or sales partners of other AGL Group members: Your name, address and contact details, so we can contact you about products you may be interested in.
• If you are a business contact for our customers or service providers: Your name, job title and contact details.
• If you are a customer of other AGL Group members: Your date of birth, your customer number with the AGL Group member, your preferences regarding direct marketing and telemarketing, information regarding complaints, hardship attributes, billing and payment information, and your energy usage and consumption information. We may also collect certain sensitive information (such as whether you require priority assistance, where that reveals health information), with your consent.
• If you apply for a job with us: Professional background, qualifications and memberships, and references from your former employers. Where it is relevant to the role, we may also collect screening check information (such as background, medical, drugs and alcohol, criminal records, bankruptcy, directorship and company checks), and abilities testing, including psychometric testing.
The Privacy Act protects your sensitive information, such as information about your health or ethnicity. Where we need this information for your account (for example, to ensure continuous service to your property or to assist with translation services), we’ll ask for your permission — except where otherwise allowed by law.
4. How do we use your information?
We use your information to deliver our products and services, manage our business and comply with the law. We also use your information for other reasons, such as to better understand you and your needs.
We collect and use your information, so we can:
• confirm your identity
• provide you with the products and services that you have asked for, including providing you with customer support
• handle payments and refunds
• communicate with you about your account
• manage your credit arrangements with us
• manage accounts that are overdue, including where we sell debt
• participating in credit reporting systems
• respond to applications, questions, requests or complaints that you have made to us
• maintain and update our records and carry out other administrative tasks
• research the usage of, and to develop and improve the capabilities of, our services
• improve customer experience and do market research
• if you have applied to work with us, assess your application
• investigate possible fraud and illegal activity
• comply with laws, including assisting government agencies and law enforcement investigations, and
• manage our business.
We may also collect and use personal information to assist other AGL Group members with any of the above activities, whether conducted by us or by the AGL Group member. If we don’t have your personal information, we may not be able to do these things. For example, we may not be able to deliver the products or services you have asked for or respond to your questions.
We, and other AGL Group members, may also use your personal information to tell you about products or services that any of us think you might be interested in, including products and services offered by other members of the AGL Group. We, and other AGL Group members, may send you marketing messages in various ways, including by mail, email, telephone, SMS, and digital marketing including advertising through any AGL Group apps, websites, social media or third-party websites.
If you tell us how you would prefer to be contacted, we will contact you in that way where we can.
If you don’t want to receive direct marketing messages, you can opt out by:
• contacting our Customer Service Centre (by emailing email@example.com or calling 13 14 64, or see section 10 below), or
• following the instructions in any marketing communication you receive from us (for example, using the ‘unsubscribe’ link in an email or responding to an SMS as instructed)
Please note that we may still send you important administrative and safety messages even if you opt out of receiving marketing communications.
The way we use data
We’re always working to develop and improve our products and services, and improve our processes to ensure that they and we better meet your needs.
New technologies let us combine information we have about our customers and users with data from other sources, such as other AGL Group members, third-party websites or the Australian Bureau of Statistics.
We also collect information about people that does not identify them such as website and advertising analytics, and data from service providers.
We, and other AGL Group members, may analyse this data to help each of us learn more about our customers and improve all of our products and services. Where we work with partners or service providers to do this, we do not pass on personal information about you.
5. Who do we share your information with?
We share your information for the purposes set out in section 4, with members of the AGL Group, our service providers, and to comply with the law. When we do this, we take steps to keep your information safe.
We share your personal information with other people and companies where we need to for the purposes set out in section 4. This includes sharing:
• with other members of the AGL Group so they can carry out any of the purposes set out in section 4
• with our installation, maintenance and fulfillment partners and other third party service providers, such as nbn co limited, so they can make installations and maintain products and services that we offer
• with other telecommunications service providers and organisations which deliver our products and services or transfer your phone number if you change telecommunication service providers
• with our wholesalers and other customers from or through whom you may acquire or services
• with credit reporting agencies to process new applications, assess and manage applications for credit, manage overdue accounts, and review your creditworthiness
• with insurance investigators
• with people that you have asked us to give your information to, such as your authorised representatives or legal advisors
• if you have applied to work with us, with your previous employers to confirm your work history
• to comply with laws and assist government agencies and law enforcement.
We also share personal information with people and organisations that help us with our business, such as professional advisors, market researchers, IT support, and corporate and administrative services including mercantile agents (including debt collectors) and debt buyers. We only do this where it’s needed for those services to be provided to us. When we do this, we take steps that require our service providers to protect your information.
The credit reporting body we use is:
Illion (credit reporting & default listing)
PO Box 7405, St Kilda Road, Melbourne VIC 3004
Online contact form
Phone: 13 23 33
You can contact this credit reporting body or visit its website to see its policies on the management of credit-related information, including details of how to access your credit-related information it holds. You have the right to request the credit reporting body not to:
• use your credit-related information to determine your eligibility to receive direct marketing from credit providers; and
• use or disclose your credit-related information, if you have been or are likely to be a victim of fraud.
Sending personal information overseas
Some of our service providers are located or operate outside of Australia. Where we need to, we send them information so that they can provide us services. The countries where our service providers may be located include India, Indonesia, Fiji, New Zealand, Canada, Japan, Malaysia, Singapore, the Philippines, South Africa, the USA, the UK and some member states within the European Union.
When you are visiting our website, cookies may be used to collect information such as the number of users who visit our site, the date and time of visits to our site, the number and type of pages viewed, and navigation patterns.
• understand how our website is used
• improve our website
• recognise you when you return to our website and provide a customised website view based on your previous usage of the website
• provide you with more relevant and tailored offers via email, mail or phone
• use the services of our online advertising partners to deliver targeted advertising across sites in their networks, for example:
o remarketing, whereby our online advertising partners will reach out to people who previously visited our website
through advertisements on sites in their networks
o behavioural targeting, whereby our online advertising partners will be classifying our website visitors according to how
they use our website and deliver targeted ads on sites across their networks.
You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.
Each browser is different, so check the ‘help’ menu of your browser to learn how to change your cookie preferences. For example, in Google Chrome you can disable or delete cookies by selecting “Settings/Privacy/Content Settings/”.
Please note that our services and our website are designed to work with cookies and disabling cookies may affect your usage of our services or our website and may prevent you from taking full advantage of our services. We do not exchange cookies with any third party websites or external data supplies, except with third parties working with us to provide our services to you.
Some of our advertising services utilise third party cookies. You can choose to permanently opt out of the advertising cookies sent by our online advertising partners by visiting their websites, referring to the ads setting and downloading the browser plugin.
7. Keeping your information safe
We train our staff in how to keep your information safe and secure. We use secure systems and environments to hold your information. We only keep your information for as long as we need it.
We take steps in accordance with the Guide to Securing Personal Information published by the Office of the Information Commissioner, to secure our systems and the personal information we collect.
Here are some examples of the things we do to protect your information.
Staff obligations and training
We train our staff in how to keep your information safe and secure.
We store your information in secured systems which are in protected and resilient data centres.
Services providers and overseas transfers
Our websites and apps
Destroying or de-identifying data when no longer required
We aim to keep personal information only for as long as we need for our business or to comply with the law.
8. Accessing, updating and correcting your information
You can ask us for a copy of the personal information or credit-related information that we hold about you, or ask us to update or correct it, by contacting us. Before we give you your information, we will need to confirm your identity.
You can also log in to your account to access your billing information and update your contact and payment details. To access other information, you may need to contact us.
How can you contact us?
See section 10 for details on how you can contact us.
How long will it take?
We try to make your information available within 30 days after you ask us for it. If it will take longer, we’ll let you know.
Can we refuse to give you access?
In some cases, we can refuse access or only give you access to certain information. For example, we’re not able to let you see information that is commercially sensitive. If we do this, we’ll write to you explaining our decision.
Can you correct or update your information?
You can ask us to correct or update any of your personal information or credit-related information that we have. If we’ve given the information to another party, you can ask us to let them know it’s incorrect.
If we don’t think the information needs to be corrected, we’ll let you know why. You can ask us to include a statement that says you believe our record about you is inaccurate, incomplete, misleading or out of date.
9. Making a privacy complaint
How can you make a privacy complaint?
If you are concerned about your privacy or how we’ve handled your personal information, let us know and we’ll try to fix it. See section 10 for details on how you can contact us. If you’re not satisfied with how we handled your complaint, you can contact the Australian Privacy Commissioner.
You can read more about how we handle complaints by reading our Complaints Handling Policy.
How do we manage privacy complaints?
• keep a record of your complaint
• respond to you about your complaint and let you know how we will try to resolve it and how long that may take.
What else can you do?
If you’re not satisfied with how we have managed your privacy complaint, you can contact the Telecommunications Industry Ombudsman at any time for advice or to make a complaint. The Ombudsman is independent, and their services are free.
Online complaint form
You can also complain to the Australian Privacy Commissioner who can be found at the Office of the Australian Information Commissioner (OAIC).
Office of the
Phone: 1300 363 992
10. Contact us
To ask us a question, access your personal information, request a correction to your personal information, make a complaint, or get a printed copy of this policy, you can contact our Customer Service Centre.
Phone: 13 14 64
Fax: 1300 763 744