We are bound by the Australian Privacy Principles of the Privacy Act 1988 (Cth) (Privacy Act) in our handling of your personal information. We are also bound by Division 3 of Part IIIA of the Privacy Act, and the Credit Reporting Privacy Code (CR Code) in our handling of your credit-related personal information. References in the policy to "information" include both personal information and credit-related personal information.
We may tell you more about how we handle your information at the time we collect it.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, such as your name or address.
Personal information may be sensitive information, which includes, for example, information about an individual's health, membership of professional bodies and religion.
Credit-related personal information is a variety of personal information that includes information about your credit history or creditworthiness. It includes information about your past experiences with us and other lenders, the kinds of credit products you have had or sought, how you have managed your obligations, information contained in a credit report about you which is obtained by us from a credit reporting body (CRB) and information about your creditworthiness that has been derived by us from such a credit report about you.
We collect personal information (including, if you apply for or enter into a loan with us, credit-related personal information) about you and about your interactions with us, for example, transactions on your account.
The information we collect may include your name, address and contact details and information specific to a product you seek such as (if you apply for a loan) details of your financial position, employment and your reasons for seeking the loan.
If you apply for a loan, we may collect information about you from third parties (for example, your employer and CRBs) in order to assess your eligibility for the loan. We may also collect information about you from publicly available sources.
We are obligated to take extra care under the Privacy Act in our collection of your sensitive information, such as health information. If we need to collect such information, for example, in connection with assessing whether you have a pre-existing medical condition for insurance purposes, we will ask for your consent.
We are required by the Anti Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and, if you are giving a mortgage, certain State property laws (for example, the Real Property Act 1900 in NSW) to collect information to identify you, and by the National Consumer Credit Protection Act 2009 (Cth) to learn about and verify your financial situation. We are permitted to collect, but you are not required to provide, your Tax File Number under the Taxation Administration Act 1953 (Cth) and the Income Tax Assessment Act 1936 (Cth). Information is requested about tax residency of other countries in order to help us comply with taxation laws including Common Reporting Standard, Foreign Account Taxation Compliance Act and non-resident withholding tax.
If you do not provide some or all of the information we request, we may be unable to provide you with a product or service.
We use and exchange your information for the main purpose of providing you with a product or service and to manage our relationship with you, including to:
Generally, we will not use or exchange your information for any purpose other than one that:
We may exchange your information for any of the reasons mentioned above with third parties including:
When we disclose your information to third parties, we limit their use and disclosure of that personal information to the specific purpose for which it is disclosed and require them to protect your information in accordance with the Privacy Act.
We may obtain a credit report about you from a CRB. A credit report will provide us with information about you that is held by the CRB and which has any bearing on your creditworthiness.
We may use this information to arrive at our own assessment of your creditworthiness.
Further, to enable us to verify your identity, we may disclose your name, date of birth and residential address to a CRB for the purpose of obtaining an assessment of whether that personal information matches information held by the CRB.
We may disclose to a CRB any failure by you to meet your payment obligations in relation to consumer credit and the fact that you have committed fraud or other serious credit infringement.
The CRBs we may use from time to time include:
Dun & Bradstreet
CRBs may include information which we provide in reports to other credit providers to assist them to assess your creditworthiness.
You can ask a CRB not to use or disclose credit information it holds about you for a period of 21 days (called a "ban period") without your consent if you believe on reasonable grounds that you have been or are likely to be a victim of fraud, including identity fraud. If you are applying to be a borrower, guarantor or security provider, you agree to us accessing your personal information (including credit information) held with a CRB, even if there is a ban period in place, for the purposes of assessing an application for credit or in order to collect overdue payments.
CRBs may use credit information they hold to respond to requests from us or other credit providers to "pre-screen" you for direct marketing. You can ask a CRB not to do this. However, if you are a borrower you may still receive direct marketing from us (unless you ask not to) that has not been "pre-screened".
We keep your hard copy or electronic records on our premises and systems or offsite using trusted third parties. We take all reasonable steps to ensure that information we hold about you is protected from:
Your information is only accessible by you and those authorised to access it. Employees and third parties who deal with your information are bound by confidentiality obligations and are required to complete training about information security.
When you transact with us on the internet via our website, we encrypt data sent from your computer to our systems. We have firewalls and virus scanning tools to protect unauthorised access. When we send electronic data, we use dedicated secure networks or encryption.
When we no longer need your information, including when we are no longer legally obliged to keep records relating to you, we will destroy it or de-identify it.
We take all reasonable steps to ensure that the information we may collect, use or disclose is accurate, complete and up-to-date. You have rights to access your information and correct it if it is inaccurate, out-of-date or incomplete.
You may request access to the information we hold about you at any time by contacting the Member Advocate on 13 25 77 or at [email protected]. We will respond to your request within a reasonable time. There is no fee for making a request but we may charge you the reasonable costs of providing our response to a request for access to personal information.
If we refuse to give you access to any of your personal information, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act on which we rely to refuse access.
You may also ask us to correct any information we hold about you by contacting us using the details noted above. We encourage you to advise us as soon as there is a change to your contact details, such as your phone number or address. We will deal with your request to correct your information in a reasonable time. If we correct your information and it is information we have provided to others we will notify them of the correction where we are required to do so by the Privacy Act. If your request to correct your information relates to information which has been provided to us by a CRB or another credit provider we may need to consult with them about your request. We will correct information, where we decide to do so, within 30 days of your request, or longer if you agree.
If we do not agree with the corrections you have requested, we are not obliged to amend your information accordingly, however, we will give you a written notice which sets out the reasons for our refusal.
We may use your information to advertise or promote products, services, or business or investment opportunities we think may interest you, including by email or telephone. We may also provide your information to other organisations for specific marketing purposes. However, we will not do so where you tell us not to.
You can ask us not to contact you about products and services and not to disclose your information to others for that purpose by calling us on 13 25 77.
Additionally, if you believe that in handling your personal information we have breached the Australian Privacy Principles, Part IIIA of the Privacy Act or the Credit Reporting Code and you would like to make a complaint, you may use these same contact details noted above to lodge a complaint.
Once we receive your complaint, we will respond to you as soon as possible and will let you know if we need any further information from you. We will notify you of our decision within 30 days, however if we are unable to do so, we will let you know the reason for the delay and the expected timeframe to resolve the complaint.
If you are not satisfied with our response to your complaint, or the way in which we have handled your complaint, you may contact the Australian Financial Complaints Authority (AFCA), our external dispute resolution scheme, or the Office of the Australian Information Commissioner. The contact details of these entities are as follows:
Australian Financial Complaints Authority
Office of the Australian Information Commissioner
Either of these entities may forward your complaint to another external dispute resolution body if they consider that the complaint would be better handled by that other body.
Creditworthiness: An assessment of your creditworthiness includes an assessment of your:
1. eligibility to be provided with credit, (e.g. over 18 years old)
2. repayment history in relation to prior credit obtained by you, and/or
3. your ability to repay an amount of credit (i.e. sufficient earnings).
Credit history: A record of a borrower's responsible repayment history in relation to credit provided which can be obtained from a Credit Reporting Body. Information is sourced from banks, credit card companies, collection agencies, and government agencies.
Consumer credit products: A consumer credit product would be typically known as a home loan, investment home loan, credit card and/or personal loan that is used for:
1. personal, family or household purposes, or
2. to acquire, maintain, renovate or improve residential property, or
3. to refinance credit that has been previously provided to acquire, maintain, renovate or improve residential property.
Credit reporting body (CRB): A credit reporting body (CRB) is an organisation whose business involves handling personal information in order to provide another organisation with information about the credit worthiness of an individual. A consumer credit report will confirm if you have consistently met your repayments on time and/or if you have not defaulted on a repayment.
Interaction/s: Communication or direct involvement with you. It can include face-to-face, online, phone, email, text and transaction/credit product apps.
Contact details: The information required to contact someone, such as an address, phone number or email address.
Eligibility: Minimum criteria required to be met (e.g. age).
Publicly available sources: Information that is generally available to a wide range of persons. Some examples include names and addresses in telephone books and information published in newspapers or other public media.
Tax residency: This relates to those people who have taxation obligations in other countries. (e.g. US Citizen).
Signatory: A party that has signed an application for an account that they are authorised to operate.
Guarantor: A party that gives or acts as a guarantee on an application. They guarantee to pay a main borrower’s debt if the borrower does not meet their loan repayment obligations. They usually need to pledge their own assets as a form of security.
Representative: A person chosen or appointed to act or speak on behalf of another.
Personal Property Security Register (PPSR): A national online database that stores information of security interests (outstanding debts etc.) on personal property such as cars, boats and most other assets apart from real estate (land or buildings). The register is administered by the Insolvency and Trustee Service Australia (ITSA) and is searchable by consumers and businesses.
Dispute resolution bodies: An independent organisation (Australian Financial Complaints Authority) that assists you in the event that you are unable to reach a satisfactory agreement in relation to a complaint or dispute lodged with a financial institution.
Credit infringement: This is when you default under your contract. This can include not paying the amount required and is overdue by 60 days or more or giving false and misleading information either before or after obtaining a credit product.
De-identify: The removal or alteration of personal identifiers, followed by the application of any additional controls required to remove, obscure, alter and/or protect data in some way so that it is no longer about an identifiable individual. This can include addresses, dates of birth and tax file numbers.
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