Family and Domestic Violence Policy

Purpose

This policy outlines how Greater Western Water (GWW) employees and contractors support all customers affected by family and domestic violence and the importance of prioritising the privacy, safety and confidentiality of customers affected by family and domestic violence.

GWW recognises the significance of family and domestic violence as a problem in society and our obligation to contribute to prevention efforts and mitigate risks of its products, services, systems, and processes being exploited to cause harm.

GWW condemns the perpetration of family and domestic violence in all its forms and recognises the short and long-term significant impacts family and domestic violence has on all victim survivors, their families and society.

GWW understands the unique role essential services can have in supporting victim survivors of family and domestic violence and is committed to supporting our customers affected by family and domestic violence. This aligns with our vision for thriving people and Country. Our people are our employees, partners, customers and communities. Our vision is to deliver trusted water services in a way that supports people to thrive economically, socially, environmentally and culturally.

This policy informs our decisions and actions when supporting customers affected by family and domestic violence, and ensure we meet the obligations outlined in the Essential Services Commission Water Industry Standard - Urban Customer Service Version 4, incorporating amendments as at 1 July 2024 (Water Industry Standard).

Scope

This policy applies to all customers who are identified as affected by family and domestic violence. GWW understands that customers may be identified as affected by family violence themselves by self-identifying, by GWW, by an independent financial counsellor or case worker, or by another professional acting on behalf of and with the consent of the customer. This includes any business customer that requires the support outlined in this policy. For example, a family-owned business owner operating under a business name may also be eligible for support as described in this policy. We are also aware that any of our customers could be affected by family and domestic violence, and that they may not want to be identified and may be supported differently.

Objectives

The objective of this policy is for GWW employees and contractors to support all customers affected by family and domestic violence. Through this policy, we commit to supporting our people to prioritise the privacy, safety and confidentiality of customers affected by family and domestic violence with specialised, tailored services for customers who need our support, build trust amongst our community, and bring our vision of ‘thriving people’ to life.

In meeting our objectives for Customer Experience, GWW supports our vision and strategic objectives:

Our vision is for thriving people and Country

Improving customer experience by understanding what matters most to our customers and communities. We will continue to:

• Implement our Community Engagement Framework to ensure customer and community voice is heard and used in decision making.
• Support customers experiencing payment difficulties in the face of cost-of-living pressures.
• Improve our customer service to ensure customers feel supported raising issues and are confident in our ability to resolve them.
• Build awareness of all types of family and domestic violence.

Definitions

Family violence is defined under the Family Violence Protection Act 2008 (Vic) as:

(a) behaviour by a person towards a family member of that person if that behaviour:

(i) is physically or sexually abusive; or
(ii) is emotionally or psychologically abusive; or
(iii) is economically abusive;
(iv) is threatening;
(v) is coercive; or
(vi) in any other way controls or dominates the family member and causes that family member to feel fear for the safety or wellbeing of that family member or another person; or

(b) behaviour by a person that causes a child to hear or witness, or otherwise be exposed to the effects of, behaviour referred to in the paragraph (a).

Contact Us

• When it is safe to do so, we recommend that customers contact us on 13 44 99 and select the family and domestic violence option in the menu for prioritised support Monday to Friday 8.30am to 5pm.
• In cases where family violence is identified (including through disclosure), we will refer the customer directly to our Community and Care team specialised support. All their details and information will be kept strictly confidential.
• Our Community and Care Team undergo specialised family and domestic training annually to ensure they can provide a safe and respectful environment to support disclosure.
• Once a customer is in our program, they will be given a direct line to call so they won’t have to repeat their story.
• We provide a free translation and interpretation service for non-English speaking customers. Customers should call 9313 8989 and tell us their preferred language to connect to an interpreter.
• For hearing impaired customers, we offer the National Relay Service on 13 36 77.
• We also provide access to translated information in 23 different languages, which can be viewed on our website.

Commitment

We recognise that victim survivors of family and domestic violence experience a broad range of behaviour that is not limited to physical violence. This can often include economic, emotional or psychological abuse, coercive control and other forms of family and domestic violence that will require different kinds of support, depending on individual circumstances.
We recognise that family and domestic violence affects people of different genders, and we acknowledge that the probability of violence against women is higher. Gender inequality may be compounded by other forms of disadvantage or discrimination that a person may experience based on Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes.
To achieve our vision when supporting customers affected by all forms of family and domestic violence, we commit to the following:

• We will incorporate safety by design principles in the development of products, services, systems, and processes and auditing of these to mitigate the risk of people exploiting our products, services, systems and processes to use violent and/or controlling behaviours to harm family members.
• When a customer advises GWW that they are affected by family and domestic violence, we will offer them the opportunity to have their account locked down. This means their account will be managed and viewed only by our Community and Care team, empowering the customer the right to choose the level of security applied to their account. GWW does not require evidence and will take people at their word.
• We will proactively identify customers who may be affected by family and domestic violence to introduce them to our Community and Care team for support.
• We will work with the customers affected by family and domestic violence to provide a careful and sensitive response to achieve the best outcomes for their individual circumstances safely, respectfully and confidentially.

Protecting confidentiality, privacy and safety

• We respect the privacy and confidentiality of all our customers and individuals. We protect all customer records, including the information of customers that may be affected by family violence. For specific information, see GWW’s Privacy Policy
• We will empower and support customers to manage any financial impacts and help them keep their information safe. We will provide ongoing account management that aims to meet their needs in the moment and supports them to move forward.
• We will provide a safe environment for customers to access relevant information and support. We acknowledge in the community the fear of consequences of disclosing their circumstances, mistrust of service providers, shame, embarrassment, language, cultural barriers and the fear of the perpetrator finding out.
• For all customers, we will not discuss the details of the joint account holder, including with any perpetrator – specifically;
  • For joint owners accounts where both names are on the title to the property, we will not discuss any personal details (including postal or contact details) with the other owner/s;
  • For tenancy accounts in a joint name, we can create a new account for customers, in their name only.
• Each case will be managed with sensitivity and respect. We acknowledge that each individual will need to be assessed on a case-by-case basis. When supporting those who are experiencing difficulties we will: promote the agency of the customer and family members at risk by considering their wishes and plan for the safety of all family members.
• The Customer Support Program can apply a secure flag for additional safety measures to protect against perpetrator access as only our Community and Care team will have access to secure customers’ personal information. These support measures ensure no contact is required by affected customers, with the perpetrator in relation to that customer’s GWW account.
• If we apply a flag to the customer account, that flag will further protect privacy by:
  • masking all personal information so only the Community and Care team can see the detail keeping it confidential in line with our policies and relevant legislation;
  • alert other GWW employees to transfer any calls or enquiries to the case managers who are trained and skilled to effectively manage perpetrator interactions, ensuring the privacy, safety and confidentiality of customers experiencing family and domestic violence are protected;
  • enable additional security measures for joint accounts when perpetrators still require some access to the account. This may include a password or secret question and answer.

Financial assistance and debt management

• We will provide personalised assistance to customers affected by family and domestic violence who are experiencing or are affected by financial difficulties, either short or long-term.
• GWW provides protection from the perpetrator applying for a refund of payment made by the person affected by family and domestic violence.
• For customers affected by family and domestic violence we provide access to the full range of financial supports offered through the Customer Support Policy, considering the customer’s situation and capacity to pay, which may include:
  • flexible payment arrangements, grants, debt waivers or deferment, referral to Utility Relief Grant Scheme and concessions;
  • exemption from further recovery action or restriction of supply, including waiving any prior interest accrued on outstanding amounts, exemption from further accrual of interest, waiving or suspending late fees and suspending the sale of debt or legal action;
  • provide information on how to reduce water use, improve water efficiency and referral to relevant government water efficiency programs.
• We will provide additional support and assistance for customers affected by family violence who are left with debt. We recognise customers with joint accounts face barriers to accessing support with debt. We provide tailored support and security measures for these customers.
• We may waive all or part of their debt based on several factors, including:
  • the amount of debt;
  • the circumstances in which the debt was incurred (including if it was incurred because of financial abuse);
  • the payment assistance options that have been (or could be) effective;
  • the customer’s personal circumstances and capacity to pay the debt.

If a customer’s circumstances change, we will work with them to ensure that the debt assistance applied also changes and adapts as required.

Training and awareness

We support all employees and contractors working with customers who may be affected by family and domestic violence to deal compassionately and sensitively with customers, through:

• induction and annual training for all employees, covering privacy and family and domestic violence awareness training with supporting processes to build and maintain the required knowledge to respond appropriately to customers affected by family and domestic violence;
• through specialist training of all customer facing employees to recognise family and domestic violence in all its forms, how to respond appropriately and referral options for specialist support. This includes how to deal appropriately with perpetrators while prioritising the confidentiality, privacy and safety of the victim survivor;
• providing access to supervision or counselling to support employees in their roles when working with customers affected by family and domestic violence;
• building awareness of gender equality and how GWW is progressing gender equality through a Gender Equality Action Plan.

While GWW strives to provide exceptional customer service, we understand that some customers may not be satisfied. Our Complaints Resolution Policy outlines our commitment to addressing complaints fairly, promptly and professionally. Customers have the right to lodge a complaint with the Energy and Water Ombudsman Victoria or other dispute resolution forum if they are not satisfied.

Community help and support

Strategy/implementation

This policy is implemented through our annual business planning cycle, which monitors our policies and identifies areas for action, resourcing requirements and timeframes for delivery. It guides our Residential Customer Charter 2024-2028, Customer Support Program, Customer Experience employee behaviours and related management processes.

All Customer Experience employees will be trained in the Family and Domestic Violence Policy and related processes during induction, supplemented by refresher training and coaching to ensure customers are treated with sensitivity and respect.

The policy is published on the GWW website, and every effort will be made to provide resources in different languages. A copy can be emailed or posted to our customers on request.

Roles and responsibilities

The Board is responsible for overseeing implementation of this Policy.

The Executive Leadership Team (ELT) is responsible for incorporating our responsibilities under this policy into our business planning activities.

The General Manager of Customer Experience is responsible for directing, reviewing, and reporting on the implementation and ongoing management of the Family and Domestic Violence Policy for our customers.

Senior Leadership Team and Team Leaders are responsible for ensuring customer facing employees are trained in the Family and Domestic Violence Policy (including related programs) and can sensitively engage with customers.

All employees are responsible for complying with relevant GWW policies, guidelines and processes related to this policy for developing an understanding of how their work functions are affected by this policy.

References and related documents

Other relevant GWW Policies, Procedures and Guidelines include:

• Ending family violence – Victoria’s 10-year plan for change
• Essential Services Commission Water Industry Standard - Urban Customer Service Version 4 incorporating amendments as at 1 July 2024
• The Residential Customer Charter 2024 -2028
• Customer Support Policy
• Information Security Policy
• Privacy Policy
• Complaints Resolution Policy
• Social Policy
• Risk Management Policy
• Family and Domestic Violence - Employee Policy

Review process

The policy will be reviewed annually.
Approved by the Executive Leadership Team (ELT) on 17 April 2025.
Next due for review by the ELT in April 2026.