Privacy Policy

Privacy Policy

This is the privacy policy (“Policy”) of Interlink Roads Pty Ltd, the operator of the M5 South West Motorway (“M5”) and the E-way tolling service provider (“E-way”) (collectively “Interlink”, “we” and “our”). This Policy applies to all of the collection, use and disclosure of personal information by us, including in respect of the M5 and E-way.

A number of the aspects of our operations have the potential to involve collection, use and/or disclosure of your personal information. This Policy shows our ongoing commitment to the protection of your personal information, whether or not you are a customer of ours. As part of our commitment to the maintenance of procedures and practices to enhance your privacy and protect your personal information we comply with the recommendations of Australian Standard AS 4721 Personal privacy practices for the electronic tolling industry. In addition, as an “APP entity” (as defined in the Privacy Act 1988 (Cth)), we comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

The personal information obtained from monitoring of our customers' toll road usage will be used or disclosed only for the purposes specified in this Policy, unless specific permission is sought from and granted by you or the use or disclosure is authorised or required by law or by order of a court or tribunal.

1. Collection

We will, wherever possible, collect information directly from you including your name, date of birth, address and any other contact details. However, we may also collect information about you from NSW Roads and Maritime Services (“RMS”) from time to time including your name, date of birth, address and any other contact details, your driver’s licence number and identification details of the vehicle you were operating (“RMS Information”), as permitted by the Road Transport (Vehicle Registration) Regulation 2017 (NSW) and the Road Transport (Driver Licensing) Regulation 2017 (NSW) (“NSW Laws”).

We collect and record information about your vehicle movements when you use the M5 and/or an E-way tag on any toll road. While the data collected by our electronic toll collection systems relate directly to vehicles rather than individuals, we do have the ability to link this information with individual vehicle owners and/or drivers and usually do so for the purposes of processing your application for a toll account, maintaining and administering your toll account and tag/card, billing, answering customer queries, resolving complaints and/or providing information to New South Wales Government agencies as permitted or required by law.

Using the M5

  1. An image of your vehicle and its licence plate number (“LPN”) is collected and recorded automatically when you pass through any toll collection point on the M5, together with the time and date of travel, lane number, the direction of travel, toll value and tag information.
     
  2. If the tag is valid on the day of travel (or if you pay your tolls using your LPN or an electronic pass product), we will seek payment from your toll account provider (which could be E-way or another toll account provider).
     
  3. If the toll is not paid or the tag is invalid on day of travel, the LPN, toll collection point, lane number, the direction of travel, time and date of travel and toll value information will be given to RMS (and, after prolonged non-payment, Revenue NSW) for the purposes of collecting unpaid tolls from you.
     
  4. For the safety of our staff and other motorway users we employ video surveillance throughout our facilities and along the M5 corridor. These cameras may record an image of you or your vehicle.
     
  5. RMS also maintains video surveillance cameras at certain locations along the motorway for traffic, audit and management purposes. We cannot access these records and suggest you refer to the Privacy Policy of RMS to learn about personal information collected by the RMS cameras.

Using an E-way tag

We collect and record information about your vehicle movements when you use an E-way tag, no matter which toll road you use, as per the second paragraph of this section.

Other information collected may include:

  • if you are the second authority for a toll account we may collect date of birth to verify the authenticity of callers; and
     
  • if a toll account is linked to a business, we may collect that business entity’s ACN/ABN number.

Information about people other than customers

If a toll account applicant or holder is a business, we may collect the name and contact details of the business entity’s employees and officers. We may also collect the name and contact details of employees and officers of our suppliers and service providers, so that we can complete business transactions, purchase products and services, administer accounts, respond to customer inquiries and meet regulatory requirements.

Telephone conversations with us

When you call us or we call you, we may monitor or record your telephone conversations with us for staff training and service quality control (including dispute resolution) purposes. Those recordings will be deleted within four (4) years after the date of the call, unless we are required by law to keep them for longer.

Using our website / social media

Our website may allow you to register a user name, email address, landline or mobile phone number and password to access your account information, make changes to the information held and order products. We will collect your personal information necessary to register you and any personal information you provide during your use of this feature. Where this access is provided, the access will be confidential and protected by the specific user name and password. It is your responsibility to protect the user name and password and to prevent others accessing them. You are responsible for any material that is submitted to this website using your user name and password. We are not responsible for any activities that result from the misuse of or failure to protect your user name and password.

We also allow you to contact us through our website and certain social media. Where you provide us with your contact details, we collect your contact details for the purpose of responding to your request.

Cookies: A cookie is a piece of data stored on the user's hard drive containing information about the user. Use of a cookie is in no way linked to any personal information while on our site.

Log files: When you use our website, we use IP addresses to analyse trends, administer the site, track users’ movements and gather broad demographic information for aggregate use. We do not link IP addresses to your personal information.

Links: Our website contains links to other sites. Please be aware that Interlink is not responsible for the privacy practices of such other sites. This Policy applies to information collected by us on or via our website.

2. Use

Except as authorised or required by law or a court or tribunal order, we will only use your personal information for the purposes set out in this Policy and that are necessary to carry on our business and/or to provide services to you. We will use your RMS Information to recover unpaid tolls and for debt collection in accordance with the NSW Laws.

3. Disclosure

Working arrangements between us and other toll road operators, New South Wales Government agencies and associated legal and regulatory authorities designed to minimise the complexity of transactions, facilitate customer service and as required or permitted by law by necessity involve the transfer of your personal information to and between these parties. Except as specified in this Policy or as authorised or required by law or a court or tribunal order, we will only disclose the minimum amount of your personal information necessary for the effective and efficient management of toll roads and customer accounts. When there are proposed new uses of your personal information not contemplated by this Policy or authorised or required by law or a court or tribunal order you will be notified and given the opportunity to not participate in any such new uses or arrangements.

We may also disclose your personal information (including your RMS Information) to organisations to which we have outsourced some of our functions such as mailing houses and IT contractors (“service providers”) and, in particular, to the following organisations or types of organisations:

Nominated financial institutions: We may exchange relevant information with financial institutions nominated in your application form to process transactions.

Credit reporting agencies and credit providers: We may conduct a credit check as part of our assessment of your application for a toll account.

Credit reporting/collection agents: Where you are in default on your toll or toll account we may notify and exchange personal information where appropriate with credit reporting agencies and/or our collection agent.

RMS: We are obliged to transfer information to RMS for the purposes of Penalty Notice processing and management of the M5 Cashback Scheme (a NSW Government initiative) and any other Government scheme or relief program. We may also exchange personal information with RMS to facilitate transactions relating to the use of participating toll roads, monitoring and administering your use of the tag/card and collection of unpaid toll debts.

Service NSW: We are required by section 78 of the Roads Regulation 2018 (NSW) (i.e. by law) to provide the following personal information to RMS and Service NSW from 1 July 2017 for Service NSW to use for the purposes of management of the Toll Relief Scheme and determining your entitlement to relevant motor vehicle tax or registration fee exemptions:

  • evidence of toll payments from 1 July 2017 onwards;
  • your LPN;
  • your toll account number(s);
  • your tag number(s);
  • your participation in the M5 Cashback Scheme; and
  • periods during which toll payments were made, toll accounts were active, LPN(s) or tag number(s) were associated with particular toll account(s) and/or you were a registered participant in the M5 Cashback Scheme.

Law enforcement agencies: We will make your personal information available to law enforcement or regulatory agencies if we are served with a legally enforceable court order or such is required or authorised by law.

Other toll road operators and other tag issuers: We will exchange information with operators of participating toll roads and other issuers of tags to facilitate transactions relating to use of participating toll roads, monitoring and administering your use of your tag and collection of toll debts (including processing of violations). If arrangements under which we administer your use of a tag are terminated, or if we assign or delegate our rights and obligations to a third party, it may be necessary for us to disclose your personal information to another party to enable that party to manage your account in place of us or to enter into a similar arrangement with you. In such circumstances, we will ensure that we will not hand over personal information to another party unless that party agrees to:

  • stand by the commitments we have made to you in this Policy; or
  • inform you of changes to those commitments to enable you to close your account should you wish to do so.

We will not sell, share, or rent your personal information to others in ways different from what is disclosed in this Policy.

4. Uses of anonymo s data

We may occasionally provide de-identified or anonymous data to other organisations or traffic authorities for traffic research and planning purposes. We may also use anonymous tag data to calculate travel time between points on the motorway. This data will be stored on secure computers and will be deleted immediately following calculation of travel time. It will not be possible to correlate the data collected to individual customer data.

5. Marketing

We will not disclose your personal details to any other organisation for their marketing purposes. We may use the details on the application form to advise you of new products or services from our motorway partners or ourselves (and we may use service providers, such as a mailing house, for this purpose). If you do not want us to use your details on the form for this purpose you may request us to remove you from these notifications.

6. Security and accountability

We will take reasonable steps to manage and safely and securely store your personal information and will only hold it for the time necessary for our purposes (as set out in this Policy), our records registers and to comply with legal requirements. We will take reasonable steps to ensure that your personal information is protected against unauthorised access, use, disclosure or modification and against loss. We are open to all reasonable public scrutiny of our management of your personal information. However, we are not responsible for the use, disclosure, correction of or access to any of your personal information by any agency, entity or person to which we provide your personal information where we are required or authorised to do so by law or a court or tribunal order.

Certain Interlink personnel have access to your personal information including customers' account information for the purposes of answering queries or resolving problems. Interlink will manage the use of your personal information through a regime of access rights, password protection and supervision of the use and disclosure of your personal information. 

7. Quality of information, access, and correction

We will ensure that all information collected is relevant to the purposes for which it is intended and take reasonable steps to keep such information, accurate and complete. We ask that you help us by telling us as soon as possible if your details change.

You have the right to have access to your personal information held by us and to have any incorrect information corrected by contacting us (see section 8 below). Any complaints concerning your personal privacy will be processed through our complaints mechanism (see section 8 below).

8. Contact details & complaints

If you have any questions about this Policy or your privacy, wish to access or amend your details or wish to make a complaint in relation to privacy, you can send an email to irpl@interlinkroads.com.au.

We treat complaints relating to privacy extremely seriously. If you submit a complaint we will try our best to deal with it and get to a satisfactory outcome. If, after 28 days, you are not satisfied with our response to your complaint you could contact the Office of the Australian Information Commissioner (OAIC).

9. Notification of changes

If we decide to change this Policy, we will post the changes on our website so users and our customers are always aware of what information we collect, how we use it and under what circumstances we disclose it. Your continued use of this website, the M5, E-way or any of our services or products and/or your providing us with any further personal information is your deemed acceptance of the changes.