Contents
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Better practice in responding to family violence
- Introduction
- Principle One: Develop an informed approach that works for the organisation
- Principle Two: Lead from the top and demonstrate accountability
- Principle Three: Prioritise safety and choice for victim-survivors
- Principle Four: Build a culture of awareness, internally and externally
- Principle Five: Acknowledge and address barriers to access
- Appendices
Better practice in responding to family violence
Published 06 August 2019Protect private and confidential information
Family Safety Victoria highlights the importance of ensuring safety.51 An effective policy needs to make the victim-survivor’s safety and protection a priority from beginning to end. Perpetrators may use knowledge of their former partner’s personal information to pass standard account privacy protection methods in order to get their new contact details.
Protecting confidential information is particularly important when the perpetrator is, or has been, a joint account holder. It may also be relevant where family violence is occurring between account holders of a non-residential (business) account. Southern Rural Water, whose customers are predominantly commercial enterprises, and Coliban Water both promote a safety first approach to account security.
"If a customer requests their personal details to be suppressed because of family violence, we will do it to keep them safe. It is irrelevant whether they are a director of the business, as many of our customers are. What is important to us is that we follow through on our promise to keep our customer's private information confidential when requested to do so for reasons of family violence." – Southern Rural Water
“The new security screens on our billing systems offers piece of mind for customers as some were still going through separation or trying to leave a relationship and feared their new contact details may be disclosed.” – Coliban Water
Gippsland Water ensures its service remains safe for customers by taking a flexible approach when working with customers on account security measures. Wannon Water made process and system changes so customers could be confident about the safety of confidential information. For North East Water, customer safety measures improved customers’ confidence that the information they share about family violence is not disclosed, thus protecting customer safety and the relationship between the business and customer.
“Customers trust us to protect their information once disclosed. We understand that there may be risk in some instances of accidental disclosure but we limit the possibility by strictly adhering to our safety processes.” – North East Water
Case Study – Gippsland Water
Gippsland Water was told by a customer that her ex-partner was known to use a female friend to contact utilities in order to try and find out about her new address.
The customer was afraid of her ex-partner so the case manager decided he would not obtain a forwarding address to ensure her location could not be compromised. The customer and case manager only communicated via email to promote the customer’s safety. Gippsland Water decided that in this instance the customer’s safety was the highest priority.
Case Study – Wannon Water
Wannon Water first made changes to their billing system and customer records system to allow customers’ details and accounts to be locked down. Having this facility has given the customer relations team the confidence to reassure customers that their information will not be accidentally shared.
Wannon Water staff then considered changes to its record keeping so it could better secure documents, particularly sensitive document, and restrict access to only the support team.
Working through this process meant staff had confidence that they were keeping customers safe and the customer would know the process behind locking down these accounts and why their call would be referred to a support person to discuss with them.
In making the changes, Wannon Water considered the cost relative to the potential risk to their customers. As a result of these changes, customers can now be reassured that their details will not be shared inadvertently and that they will not need to repeat their story.
Case Study – North East Water
At North East Water all information remains confidential and disclosure to a third party (police) will only occur if they consider somebody may be at risk of harm. To support confidential and respectful conversations the following processes are implemented:
- Password protected / secret question access
- Pop up message on accounts
- Safety flag (red flashing symbol)
- Calls to be transferred to the Customer Support team
- Case managers
In some instances a (forwarding) postal address and other contact details are kept separately from the account and are only accessible to specific staff.
By putting these safety triggers in place North East Water has limited the number of people who can access certain information. North East Water acknowledges the impact this has on call volumes for the support team but considers this manageable relative to the potential adverse effects of normal practices on customers.
By engaging all staff in developing confidentiality in systems and processes, staff can help identify risks, particularly where they could lead to unintentional sharing of a customer’s account details.
Such an approach allows an organisation to implement practical solutions and create safeguards to ensure sensitive information can only be accessed by authorised staff. Lower Murray Water found that involving staff in initiatives to improve customer confidentiality, increases awareness of family violence across the business.
Case Study – Lower Murray Water
In developing its systems to protect customers’ account security, Lower Murray Water looked at its customer touchpoints where there was potential for private customer information to be divulged.
It then involved its Business Technology Services team and Rural Operations team in determining how to protect details in its Property and Rating system, Records Management System and Water Ordering system. This level of involvement across the business made the process complicated, but also ensured the outcome was comprehensive.
Lower Murray Water said as a result of this work and associated training, staff awareness of family violence and its impact on customers has increased across the business, particularly for staff working in systems where customer information is stored.
Gas and electricity retailers must not disclose or provide access to confidential information without the customer’s consent.
See 106G of the Energy Retail Code.
Water businesses must provide for the secure handling of customers information.
See clause 14(c) of the Urban Water Business Customer Service Code and clause 11(c) of the Rural Water Business Customer Service code.
Maintaining customer trust is critical to developing an effective response
Our 2019 research on the outcomes of family violence assistance in the water sector found that despite initiatives by water businesses, some customers still did not trust in businesses to protect their personal information. This can be a particular issue in regional areas where customers perceive there to be a greater risk of detection by the perpetrator due to the likelihood that either party would know someone within the business.
"When it’s a community like this, what it would fall down is if [the customer] knew the person they were talking to [on the phone] or if they knew someone that worked at the water business…They have their privacy policy but when someone is in fear it means nothing to them." – Financial counsellor
Businesses need to consider the customer’s experience when developing its information security measures, including how it communicates to customers the measures and safeguards it puts in place. It is only through doing this that customers will feel safe to disclose.