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Transwa Privacy Statement

Last Updated: July 12, 2024

 

 

Introduction

This Privacy Statement explains how Transwa, part of the WA State Government’s Public Transport Authority ("us", "we" or "PTA"), collects, uses and discloses your personal information. 

This Privacy Statement may change periodically, so please check back from time to time. For your information, the date of the last update to this Privacy Statement is stated at the top of this statement.

 

The information we collect and how it is collected

We may collect personal information (e.g. name, contact details etc.) that you choose to give us or which we may require to provide you with a particular service.

In certain areas of our website, we may ask you to provide your name, gender, date of birth and contact details by registering for the website or participating in surveys.

If you use our website to complete an online application form or booking, we will collect any personal information you provide on that form which may include your name, date of birth, gender, marital status, address, email and telephone number. We will only collect the information contained in that application form if you submit the form to us. If you log out of the website or cancel the application prior to submitting the form, the information you had entered will be automatically deleted.

Depending on the application made, we may also collect credit card or debit account details in order to provide you with our goods or services.

If you use the “Chat” function on our website or via the Transperth mobile application, we will collect any personal information you provide in the chat.

If you use our online feedback form then we will collect your name, email address and SmartRider number.

We will record your e-mail address if you send us a message.

If you have purchased a SmartRider or SmartCommuter card, we will collect information relating to your use of public transport and travel concession details.

If you park at a public transport parking facility, we will collect information relating to your use of the parking facilities and motor vehicle registration details.

If you use the Transperth mobile application, we will collect information as to your activity, location, telephone number, IP address and any security incident information.

When you access this website, some technical information is collected about your visit. For example:

 

  • your server address;
  • your top level domain name (for example .com, .gov, .au, .uk etc.);
  • the date and time of your visit to the site;
  • the pages you accessed and documents downloaded;
  • the previous site you have visited;
  • the type of browser you are using; and
  • what devices and operating systems you used to access the site.
 

How we use your personal information

The personal information you provide us will be used for the primary purpose for which it was collected. For example, we may use your personal information to administer our services to you, manage our relationship with you, improve our services, respond to your questions or feedback, process a transaction, assist in planning and research, respond to a security incident and send you newsletters, updates, notifications or other PTA related commuter information.

We may also use or disclose your personal information, including information collected using cookies:

  • for a purpose made known to, or authorised by, you;
  • for a purpose related to that for which it was collected if you have consented to that use or;
  • disclosure, or if you would reasonably expect the personal information would be used for that
  • related purpose;
  • where required, authorised or permitted by or under any law or to enforce any law;
  • where necessary to prevent or lessen a serious threat to the life, health or safety of any
  • individual, or to public health or safety;
  • where required to take appropriate action in relation to suspected unlawful activity or serious
  • misconduct or a reported security incident;
  • where required to assert or defend a legal or equitable claim or to conduct an alternative dispute
  • resolution process;
  • for marketing (including direct marketing) purposes;
  • for research or planning purposes; or
  • where required to locate a person reported as missing.

Your personal information will at all times be dealt with in accordance with the applicable legislation in Western Australia and consistent with any legal obligation (including the State Records Act 2000). 

 

Sharing of your personal information

We may provide your personal information to other entities including:

  • contractors who provide certain services related to our services. These services include, but are not limited to, information technology support, electronic funds transfer services, credit card account processing and related services, call centre support, security services, production of cards, marketing, research and planning; Ministers and other government departments, agencies or entities;
  • our internal and external auditors;
  • law enforcement agencies or regulators;
  • emergency services providers;
  • research and marketing entities for the purposes of research, marketing and planning; and
  • investigators and entities engaged to help identify and investigate improper activities or prevent fraud.

 

Your personal information may also be shared between our business areas, including Transperth and Transwa.

 

Use of cookies

When you visit our websites, some statistical information is collected about how you interact with the website. We use cookies to collect this type of information. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable us to recognise you across different websites, services, devices and/or browsing sessions. We use cookies to deliver content specific to your interests so you do not have to register each time you use the website. You can disable cookies through your internet browser but if you do so, some of the features on our websites may not function fully and your ability to browse, read and download information may be impaired.

 

We use online tools to gather information about visitors to our website and to help us improve our website and deliver services. We use software provided by third party vendors for this purpose.

 

Social Media

We may also use third-party websites and platforms for interactive sharing and to connect with you. This includes social media platforms, including but not limited to, Facebook, TikTok, Instagram, Twitter, LinkedIn and YouTube.

When you browse and make use of our social media platforms, you are using an external site and are therefore subject to the privacy policies and practices of that site. These third-party sites may allow them to use your personal information in ways that will be different to the way we use and disclose your personal information. If you have any questions or concerns regarding that site’s privacy policies and practices, you should review the privacy statement of the relevant site. We do not exercise any control over the management of those sites and do not endorse, and are not accountable for, any views expressed by third parties using or providing those sites.

We may record and monitor information posted to our social media channels and use that information for the purposes of administering the channels, for record keeping, for considering and/or addressing any comments made, for direct marketing and for running competitions and campaigns.

We use Facebook’s Pixel to gather information. It collects data that helps us track conversions from Facebook ads, optimise ads, build targeted audiences for future ads, tailor content and remarket to people. By engaging with us via Facebook, you acknowledge and agree that you also comply with terms and conditions of use of Facebook and that you consent to this use. You can choose to opt out from tailored content through your Facebook settings. However, if you change your settings and are following us on Facebook, you may still see our organic posts.

 

Disclosure of Personal Information outside Australia

We may disclose personal information, such as email addresses and subscription preferences, outside of Australia to third party contractors and suppliers, including in the United States and European Union.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with this Privacy Statement. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in away that is consistent with this Privacy Statement.

 

When you communicate with us through a social media network service such as Facebook or Twitter, the network provider and its partners may collect and hold your personal information overseas.

 

Use of Personal Information for Direct Marketing

We may send you direct marketing communications and information about our services. This may take the form of emails, SMS, telephone, mail, social medial platforms or other forms of

communication. We may also undertake direct marketing through our media service providers. By accessing this website or any social media platform, you consent to receiving such marketing communications. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided.

 

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for, and do not endorse or otherwise approve, the content, privacy policies or practices of third party websites that are linked on PTA websites, and we have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Privacy Statement. If you follow a link to another website from a PTA website, we recommend that you read the privacy statement or policy of that other website to understand what it does with your information.

 

Security

We have taken all reasonable steps to implement the appropriate security policies, rules, measures and patches to protect your personal information that we have under our control from unauthorised access or improper use. Personal information is securely stored by us and by third parties on our behalf. For example, fire walls and virus protection software are in place to protect our systems and data.

 

All personal information that is no longer required to be retained is destroyed or de-identified.

 

Access and Correction

You may request access to documents that contain your personal information which are in our possession. You may also request the correction of documents which we hold that contain your personal information if you believe that personal information is incorrect, incomplete or out of date.

In some cases, you request will be dealt with in accordance with the Freedom of Information Act 1992.

 

Contact Information

If you have an enquiry or complaint in relation to this Privacy Statement please contact info@transwa.wa.gov.au 

 

Terms of use - Transwa website and applications

Your use of the Transwa website or applications constitutes your agreement to these terms of use. 

 

No unlawful or prohibited use

You may not use the Transwa website or applications for any purpose that is unlawful or prohibited by these terms, in any manner which could damage, disable, overburden, or impair, or interfere with any other party's use and enjoyment of, the Transwa website or applications. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available or provided for through the Transwa website or applications. 

 

Use of communication services

The Transwa website or applications may contain bulletin board services, chat areas, news groups, forums, communities, personal web pages, calendars, and/or other message or communication facilities designed to enable you to communicate with the public at large or with a group ("Communication Services"), you agree to use the Communication Services only to post, send and receive messages and material that are proper and related to the particular Communication Service. By way of example, and not as a limitation, you agree that when using a Communication Service, you will not:

Defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such as rights of privacy and publicity) of others. 

Publish, Post, upload, distribute or disseminate any inappropriate, profane, defamatory, infringing, obscene, indecent or unlawful topic, name, material or information. 

Upload files that contain software or other material protected by intellectual property laws (or by rights of privacy or publicity) unless you own or control the rights thereto or have received all necessary consents. 

Upload files that contain viruses, corrupted files, or any other similar software or programs that may damage the operation of another's computer. 

Advertise or offer to sell or buy any goods or services for any business purpose, unless such Communication Services specifically allows such messages. 

Conduct or forward surveys, contests, pyramid schemes or chain letters. 

Download any file posted by another user of a Communication Service that you know, or reasonably should know, cannot be legally distributed in such manner.

Falsify or delete any author attributions, legal or other proper notices or proprietary designations or labels of the origin or source of software or other material contained in a file that is uploaded. 

Restrict or inhibit any other user from using and enjoying the Communication Services.

Violate any code of conduct or other guidelines which may be applicable for any particular Communication Service. 

Harvest or otherwise collect information about others, including e-mail addresses, without their consent.

Violate any applicable laws or regulations.

Transwa has no obligation to monitor the Communication Services. However Transwa reserves the right to review materials posted to a Communication Service and to remove any materials in its sole discretion. Transwa reserves the right to terminate your access to any or all of the Communication Services at any time without notice for any reason whatsoever. 

Transwa reserves with right at all times to disclose any information as necessary to satisfy any applicable law, regulation, legal process or government request, or to edit, refuse to post or to remove any information or materials, in whole or in part, in Transwa's sole discretion.

Materials uploaded to a Communication Service may be subject to posted limitations on usage, reproduction and/or dissemination. You are responsible for adhering to such limitations if you download the materials.

 

Materials provided to Transwa

Transwa does not claim ownership of the materials you provide to Transwa (including feedback and suggestions) or post, upload, input or submit to Transwa's website, applications or its associated services ("Submissions"). However, by posting, uploading, inputting, providing or submitting your Submissions you are granting Transwa, its contractors, subcontractors and agents permission to use your Submission in connection with the operation of their Internet businesses including, without limitation, the rights to: copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate or reformat your Submission; and to publish your name in connection with your submission. 

No compensation will be paid with respect to the use of your Submission. Transwa is under no obligation to post or use any Submission you may provide and may remove any Submission at any time in its sole discretion. 

By posting, uploading, inputting, providing or submitting your Submission you warrant and represent that you own or otherwise control all of the rights to your Submission as described in this section including, without limitation, all the rights necessary for you to provide, post, upload, input or submit the Submissions. 

 

Termination/access restriction

Transwa reserves the right, in its sole discretion, to terminate your access to the Transwa website or its applications at any time, without notice.

 

Liability

To the extent permitted by law, neither Transwa, PTA nor the State of Western Australia shall be liable to any person or entity for any loss or damage which may arise from the use of any content on the Transwa website or its applications. 

 

Social Media Public Policy (House Rules)

Policy Overview

Transwa recognises social media channels as convenient for both passengers and non-passengers to obtain news, promotions, and other information directly relevant to transport in WA.

Official Public House Rules have been developed for all members of the public who comment on, or interact with, any of the Transwa online properties. They are outlined here to ensure high quality participation, in a manner that does not infringe the rights of, or restrict the use and enjoyment of the channel, by any other person. 

 

House Rules

While Transwa supports open-dialogue, when interacting with our online media, you agree to: 

  • Participate with the intention of adding value to, or benefitting the experience of, using public transport. If it helps you and other users of Transwa to navigate the service; if it helps our employees or partners do their jobs and solve problems; if it contributes directly or indirectly to improving Transwa's services; if it builds a sense of community, then it is adding value
  • Aim to be fair, truthful and accurate
  • Take issue with the opinion, not the person 
  • Be respective of other people's reputations
  • Be gentle when pointing out someone else's error or misinterpretation 
  • Don't spam others - it makes it hard to have a real conversation
  • Remember that social updates from Transwa re written by Transwa staff
 

Things to avoid

  •  Don't use language containing expletives or hate speech 
  • Avoid writing anything racist, discriminatory, offensive, abusive, threatening, harassing, false, misleading, defamatory, or unlawful 
  • Don't use copyrighted material without the owner's permission
  • Don't use Transwa online properties for self-promotion or commercial gain

Transwa has the right to remove any post seen as breaking House Rules, as well as the right to report or block any user from which we receive a pattern of rule-breaking activity. 

 

Comment moderation

All Transwa online properties are actively monitored during normal business hours (see individual account properties for details). However, we do not have the capacity to monitor our accounts 24 hours per day, nor respond to each individual user. We will join the conversation where reasonable, when capacity allows. 

Our team reads all direct messages and public online commentary, and any recurring themes or helpful feedback are passed to the relevant people internally. 

If journey-specific or live service information is required, users are instructed to visit the Transwa website at www.transwa.wa.gov.au.

For urgent enquiries call Transwa on 1300 662 205.

 

Following

If you follow us on an online platform we will not automatically follow you back. However, being followed by Transwa does not imply endorsement of any kind. 

 

Content sharing

All content produced by Transwa on online properties, is protected by copyright. However, you are encouraged to share our content provided that you credit us as the source (by including our official social media handle for the platform you are sharing on, see individual channels for details) and do not change the sense or misrepresent us. 

 

For a formal response

Transwa social media channels are informal. If you'd like a formal response from us, please complete the feedback form on our website.