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BSB 806 015

Privacy

This Privacy  Policy dated 1 November 2019 explains how we manage your information. 

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 (credit information). We may tell you more about how we handle your information at the time we collect it. 

This Privacy Policy sets out:

What is personal information?

What is credit-related personal information (credit information)?

Collecting your information

Using your information

Disclosing your information

Disclosing information with credit reporting bodies

Protecting your information

Accessing and correcting your personal information

Direct marketing and your information

Complaints, questions and concerns

Changes to this Privacy Policy

Definitions

What is personal information?

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.

What is credit-related personal information?

Credit-related personal information (credit 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.

Collecting your information

We collect personal information (including, if you apply for or enter into a loan with us, credit 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. 

When you give us personal information about another person, you agree to inform the person that we have collected their personal information, and of the contents of this Privacy Policy. 

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.  

Using your information

We use, and exchange disclose your information for the main purpose of providing you with a product or service 

and to manage our relationship with you, including to:

  • Identify you or to verify your identity so that we can manage our relationship with you. 
  • Establish, assess, process and administer a membership or account request.
  • Assess, complete and process your application for any product or service that you make or for which you are signatory, guarantor or representative.
  • Comply with legislative or regulatory requirements.
  • Undertake internal processes including product development, strategic planning, risk management and pricing.
  • Meet  our  obligations  in  relation  to  external  payments,  credit  reporting  systems,  government  bodies  and our funding arrangements.
  • Collect overdue payments.
  • Do anything we are required or authorised by law to do.
  • Identify and (unless you tell us not to) tell you about our products and services, and those of third parties, that might interest you.

Generally, we will not use or exchange your information for any purpose other than one that:

  • is set out in this Privacy Policy;
  • you would reasonably expect;
  • is required or permitted by law; or
  • is disclosed to you and to which you have consented.

Disclosing your information

We may disclose/exchange your information for any of the reasons mentioned above with third parties including:

  • Our related bodies corporate, assignees, agents, contractors and external advisers.
  • Our external service providers, e.g. mailing houses, IT service providers and entities to help verify your identity or identify illegal activities and prevent fraud.
  • Your agents, referees, employer, executors, administrators, trustees, beneficiaries (if you are a trustee), guardians or attorneys to verify information you have provided to us.
  • Professional advisers such as lawyers, accountants and auditors.
  • Insurers or prospective insurers and their underwriters.
  • Any person with whom you make a joint application for a product or service.
  • Your current and prospective co-borrowers, guarantors, co-guarantors and security providers.
  • Any person we consider necessary to execute your instructions.
  • Law enforcement, regulatory, government and dispute resolution bodies.
  • Anyone who introduces you to us (for example, brokers).
  • Reward program providers.
  • Payment system operators or Financial institutions to or from which a payment is made in relation to any account you have or operate.
  • Other credit providers, financial institutions and debt collection agencies.
  • Credit Reporting Bodies.
  • Anyone who obtains an interest in a loan we provide to you or is considering doing so (for example, an assignee), and their professional advisers.
  • We may also include your personal information on any registers relevant to services we provide, such as the Personal Property Security Register. 

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 disclose your information to our systems support and administrative service providers located overseas. This will include our service providers in the Philippines, Netherlands, the United States of America and the United Kingdom. Where we disclose your personal information overseas, we do so on the basis that the information will only be used for the purposes set out in this Privacy Policy.  

Disclosing information with credit reporting bodies

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: 

Equifax Tel: 13 83 32

www.equifax.com.au

Experian Tel: 1300 783 684

www.experian.com.au

Illion Tel: 13 23 33

www.illion.com.au

You may obtain the privacy policy of these CRBs by contacting them on the details above. 

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".  

 

Protecting your information

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: 

•     Misuse, interference and loss; and 

•     Unauthorised access, disclosure or modification. 

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. 

Accessing and correcting your personal information

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.  

Direct marketing and your information

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. 

Complaints, questions and concerns

If you have any questions or concerns about this Privacy Policy you may contact the Member Advocate on 13 25 77 or at [email protected].

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
GPO Box 3
Melbourne VIC 3001
1800 931 678
www.afca.org.au

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
www.oaic.gov.au

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.


Changes to this Privacy Policy

We may, from time to time, update this Privacy Policy without notice to you. The current Privacy Policy will always be available at http://www.pnbank.com.au/legal/privacy.

Definitions

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.

Download a copy of the Privacy Policy

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