Enforceable undertaking in family violence customer protections
Delivering on our commitment to better protect our customers’ privacy
Enforceable Undertaking into Family and Domestic Violence Protections conclusion
The Essential Services Commission (ESC) has confirmed that Greater Western Water (GWW) has successfully completed the commitments under the Enforceable Undertaking (EU) into Family and Domestic Violence protections, marking an important moment in the organisation’s ongoing commitment to customer safety, privacy and wellbeing.
The ESC has endorsed GWW's final report, which details the significant progress made over the past two years in delivering the commitments outlined in the EU. These include:
engaged external family violence experts to review our relevant policies, procedures and processes and provide recommendations for improvements,
implemented these recommendations to embed family and domestic violence awareness, privacy protection and safety-first practices across customer interactions, systems, training and governance.
updated our Family and Domestic Violence Policy in line with recommendations from the experts and strengthening our review process with an independent review of the policy every two years by an expert with specialised knowledge in family violence.
published a simple, one-page summary of our Family and Domestic Violence Policy, available in 23 languages.
delivered family and domestic violence awareness training to all GWW employees, including specialised training for relevant team members, forming part of our mandatory annual compliance training.
added a ‘quick exit’ button on our Family and Domestic Violence Policy webpage, allowing users to quickly and discreetly leave the website if needed.
created a new dedicated Family Violence Queue available in our Interactive Voice Response (IVR) system which will connect callers directly to our specially trained Community and Care team, reducing the number of times a victim-survivor needs to retell their story
implemented a Billing Compliance Monitoring and Improvement Plan to uplift compliance assurance processes – we sample customer interactions each week to check the quality of our completed tasks and identified where we can improve our processes.
While this endorsement formally brings this EU to a close, our work and commitment continues every day to protect the privacy, safety and confidentiality of our customers and employees. Read more in our Family and Domestic Violence Policy.
In August 2024, the Essential Services Commission (ESC) accepted an enforceable undertaking offered by Greater Western Water following a privacy breach incident and shortcomings identified in our Family and Domestic Violence Policy.
The privacy breach happened in April 2023 when we sent a bill to an address different to the address the customer specified.
This error resulted in a privacy breach for the customer, who was a family violence victim-survivor.
We condemn the perpetration of family and domestic violence in all its forms and recognises the significant impacts it has on victim survivors, their families, and society.
We understand the unique role that essential service providers can play in supporting victim survivors of family and domestic violence.
We are committed to protecting the privacy, safety and confidentiality of our customers, including those experiencing family and domestic violence with sensitivity and care.
We recognise how serious this is and we regret that we let this customer down.
Last year we made a number of commitments to uplift employee capability and training, update our Family and Domestic Violence Policy and associated processes through a Compliance Improvement Action Plan (CIAP).
We are pleased to provide an update one year on about the progress we have made in delivering our enforceable undertaking commitments around Family and Domestic Violence and the implementation of our CIAP.
Greater Western Water commits to better protecting privacy of customers
The Essential Services Commission (ESC) has accepted an Enforceable Undertaking offered by Greater Western Water (GWW).
The Enforceable Undertaking relates to a privacy breach incident in April 2023 and shortcomings in our Family and Domestic Violence Policy as specified in the ESC’s Water Industry Standard – Urban Customer Service.
The privacy breach incident involved sending mail to an address not specified by a customer experiencing family violence.
As soon as we became aware of the incident, we provided immediate support to our customer and reported the matter to both the ESC and the Office of the Victorian Information Commissioner.
We have also since introduced a new billing and payments system and removed the processes and systems that allowed this to happen.
“We are sorry for the privacy breach. We have an important responsibility to prioritise the safety of our customers and their personal information, and to take extra steps to protect customers experiencing family violence,” GWW Managing Director Maree Lang said.
“This Enforceable Undertaking formalises and reinforces our commitment to providing the highest standards of data protection for all our customers.”
As part of the Enforceable Undertaking, we have committed to a Compliance Improvement Action Plan to improve our policies, systems and processes.
Over the next two years, we will:
Review and update our Family and Domestic Violence Policy and associated processes relating to the separation and creation of new accounts.
Ensure that our Executive Leadership Team, Senior Leadership Team and customer facing teams undertake specialist domestic and family violence training.
Conduct compliance checks of customer interactions to ensure customers who have separated their accounts are not coupled together in GWW’s billing system for these new separate accounts.
Appoint an independent auditor to prepare a report on our implementation of the Compliance Improvement Action Plan and provide a copy of the report to the ESC.
The purpose of this Enforceable Undertaking is to address contraventions of the ESC’s Water Industry Standard under the Water Industry Act 1994.
An Enforceable Undertaking is a written agreement between GWW and our regulator, the Essential Services Commission (ESC).
Enforceable Undertakings support the long-term interests of Victorians. They are provided by water corporations in situations where the organisation has not met ESC standards created under the Water Industry Act 1994.
For the next two years, we’ve made a commitment with the ESC to undertake range of activities to further improve our processes to better protect our customers’ privacy.
We entered into this Enforceable Undertaking with the ESC over a privacy breach incident and shortcomings in our Family and Domestic Violence Policy.
In this Enforceable Undertaking we acknowledge that we have not met our obligations, and we are committed to doing better.
Yes. We want to reassure our customers and the community that we handle all customer information securely, not just those affected by family violence, and we’re committed to achieving best practice in protecting the information of our customers. It is our responsibility to prioritise the safety of our customers and their personal information, and to take extra steps to protect customers experiencing family violence.
There’s nothing you need to do. We have been in contact with customers affected so if you haven’t heard from us, you were not impacted. Your information is safe and we are committed to handling all customer information securely. If you’re concerned you can learn more about how we protect the information of all our customers at Protecting your Greater Western Water account.
We have a range of support options we can tailor to meet the needs of our customers’ individual circumstances.
