Dated 14 September 2017
1. Our commitment to your privacy
We understand that your privacy is very important to you and that when you agree to us collecting, holding, using, and exchanging your personal information you are putting a lot of trust in us; and your trust is very important to us. That’s why we are committed to strictly protecting your privacy and being open and transparent about what we do with your personal information.
2. This policy
3. Collecting your information
Information we collect from you
Information we collect from others
4. Using your information
• establish your identity;
• assess your application for credit;
• manage the credit provided to you;
• manage our relationship with you;
• contact you;
• identify and tell you about other products or services that we think may be of interest to you;
• conduct, manage and improve our business;
• improve our customers experience with us;
• design, price and administer our products and services;
• manage our risks and help identify and investigate illegal activity, such as fraud; and
• comply with our legal obligations and assist government and law enforcement agencies or regulators.
We may also collect, use and exchange your information in other ways where permitted by law.
5. Exchanging your information
Third parties include:
• credit reporting bodies;
• other credit providers;
• any person who proposes to guarantee, or has guaranteed, repayment of any credit you have applied for or which has been provided to you;
• finance brokers, mortgage managers, agents and persons who assist us to provide our products to you;
• financial consultants, accountants, lawyers and advisers;
• persons acting on your behalf, for example guardians and persons holding power of attorney;
• any industry body, tribunal, or court;
• businesses assisting us with funding for loans;
• any of our associates, related entities or contractors;
• trade insurers;
• your referees, for example your current or former employer, real estate agent or landlord, family members or friends;
• any person considering acquiring an interest in our business or assets;
• any organisation providing online verification of your identity;
• service providers, for example mortgage insurers;
• those to whom we outsource certain functions, for example, postage, direct marketing, statement production, debt recovery and information technology support;
• persons involved in arrangements that provide funding to us, including persons who may acquire rights to our assets (for example loans), investors, advisers, trustees and rating agencies;
• claims-related providers, such as assessors and investigators, who help us with claims;
• other financial institutions, for example so that we can process a claim for mistaken payment;
• auditors, insurers and re-insurers;
• government and law enforcement agencies or regulators;
• entities established to help identify illegal activities and prevent fraud; and
• any person where we are required by law to do so.
Sending Information Overseas
6. Credit checks and credit reporting – ‘notifiable matters’
Credit Reports and Credit Information
Credit reporting bodies collect and exchange this information with credit providers, like us, and other service providers such as telecommunication companies and utilities providers
Information that we exchange with credit reporting bodies – credit-related personal information The information we exchange includes your identification details, what type of credit you have, how much you’ve borrowed, whether or not you’ve met your repayment obligations (repayment history information), whether any payments (of more than $150.00) are overdue by 60 days or more, and if you have committed a serious credit infringement (such as fraud). We may also ask the credit reporting body to provide us with an overall assessment score of your creditworthiness.
Using your credit-related personal information
Your credit-related personal information is stored with your other personal information that we hold about you (for more information please see section 7 Security).
You may seek access to and request us to correct your credit-related personal information that we hold about you (for more information please see section 9 Accessing, correcting and updating your information). You may make a complaint to use about your credit-related personal information (for more information please see section 10 Complaint Resolution).
We have physical, electronic and procedural safeguards to protect your information which is held by us. Your information, both hard-copy and/or electronic records, are held at our secure office premises and at secure offsite premises using trusted third parties.
Our office premises are protected against unauthorised access by electronic security passes which are held only by our staff, alarms and cameras. Access to information stored, including electronic records which require login and password authorisation, is restricted to our staff whose job purpose requires access. All our staff undertake information security and privacy training. We have firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems.
8. Customer rights
Credit providers, like us, may ask credit reporting bodies to use their credit-related personal information to pre-screen you for direct marketing. You can ask any credit reporting body not to do this. Also, if you have been, or have reason to believe that you are likely to become, a victim of fraud (including identity theft), you can ask the credit reporting body not to use or disclose the credit-related information it holds about you.
9. Accessing, correcting and updating your information
You may make a request by contacting us. We will process your request within a reasonable time and try to make this information available within 30 days of your request. Before we give you the requested information we will need to confirm your identity.
There is no fee for making the request, but there may be an access charge to cover the time we spend locating, compiling and explaining the information you have requested. If there is an access charge, we will give you an estimate first and ask you to confirm that you would like us to proceed, if you would like us to we do require payment up front (you may authorise to direct debit your account). Generally, the access charge is based on an hourly rate plus any other reasonable costs incurred by us such photocopying and postage.
We do not need to provide access to your information in several circumstances; for example, the information is commercially sensitive, the request is frivolous or would unreasonably interfere with another person’s privacy or be in breach of the law, or, where to provide access would pose a threat to health or public safety. If we refuse you access we will advise you of our reasons for doing so.
If your request relates to credit-related personal information disclosed to us by others, we may need to consult with credit reporting bodies or other credit providers.
We will process your request within a reasonable time and try to correct the information within 30 days. If it looks like it will take longer, we will let you know the reason for the delay and try to agree to an extended timeframe with you.
If we are able to correct your information because it is indeed inaccurate we will inform you when it is so corrected.
If we disagree with you that the information is inaccurate and should be corrected, we will inform you in writing of our reasons. You may request that we attach a statement to that relevant information noting that you consider it is inaccurate misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.
10. Complaints resolution
How to make a complaint
How we handle your complaint
We are generally able to resolve complaints within a few days, however we are unable to provide you with a response within 45 days, we will let you know the reason for the delay and try to agree to an extended timeframe with you.
Credit-related personal information complaints
If your complaint is about the way we handle your personal information, you may also contact the OAIC by calling them at 1300 363 992, online at www.oaic.gov.au or writing to GPO Box 5218 Sydney NSW 2001