Respecting your privacy
This Policy also includes our credit reporting policy, that is, it covers additional information on how we manage your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information below as credit information.
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth;
- other contact details such as social media handles;
- financial details such as your tax file number;
- credit information such as credit history, capacity and eligibility;
- your location or activity including IP address and geolocation data based on the GPS of your mobile device when accessing our services,
- information about how you interact with us and when you use internet or mobile banking, and;
- other information we think is necessary.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
If you start but don’t submit an on-line application, we can contact you using any of the contact details you’ve supplied to offer help completing it. The information in applications will be kept temporarily then destroyed if the application is not completed. We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.
How do we collect your personal information?
Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.
There are a number of ways in which we may seek information from you. We might collection your information when you fill out a form with us, when you’ve given us a call or used our website. We may also use electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
How and why do we collect AML Information?
Under Anti-Money Laundering and Counter Terrorism Financing legislation, we are required to “know our customers”. This requires us to ensure that the personal information for all our customers is correct.
How we collect your information from other sources
Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:
- we collect information from third parties (such as your broker) about the product made available to you arising out of the services we provide you;
- we need information from third parties about an application you make through us;
- we need information for fraud prevention purposes;
- we are checking the security you are offering;
- we can’t get hold of you and we rely on public information (for example, from public registers) or made available by third parties) to update your contact details; or
- at your request, we exchange information with your legal or financial advisers or other representatives;
- you have consented to third parties sharing it with us.
What if you don’t want to provide us with your personal information?
If you don’t provide your information to us, it may not be possible:
- for us to provide you with the product or service you are seeking;
- manage or administer your product or service;
- personalise your experience with us;
- verify your identity or protect against fraud; or
- to let you know about other products or services that might be suitable for your financial needs.
How we collect and hold your credit information
We will collect your credit information in the course of you answering the enquiries we make of you relating to the products or service you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
- your co-loan applicants or co-borrowers;
- your guarantors/proposed guarantors;
- your employer, accountant, real estate agent or other referees;
- your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents;
- organisations that help us to process credit applications;
- credit reporting bodies and other credit providors;
- organisations that check the security you are offering such as valuers;
- bodies that issue identification documents to help us check your identity; and
- our service providers involved in helping us to process any application you make for credit through us.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint. Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- document storage security policies;
- confidentiality requirements and privacy training of our employees;
- security measures for access to our systems; and
- only giving access to personal information to a person who is verified to be able to receive that information We may store personal information physically or electronically with third party data storage providers.
Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or deidentified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
- give you information about loan products or related services including help, guidance and advice;
- consider whether you are eligible for a loan or any related service you requested including identifying or verifying you or your authority to act on behalf of a customer;
- assist you to prepare an application for a loan;
- administer services we provide, for example, to answer requests or deal with complaints; and
- administer payments we receive, or any payments we make, relating to your loan.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services we, our related entities or a third party make available and that may be of interest to you. We will always let you know that you can opt out from receiving marketing offers.
With your consent, we may disclose your personal information to related entities or third parties for the purpose of connecting you with other businesses or products. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.
Yes, You Can Opt-Out.
You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
- telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
- identifying opportunities to improve our service to you and improving our service to you;
- allowing us to run our business efficiently and perform general administrative tasks;
- preventing any fraud or crime or any suspected fraud or crime;
- as required by law, regulation or codes binding us; and
- any purpose to which you have consented.
How we use your credit information?
We may also use your credit information to:
- assess whether to accept a guarantor or the risk of a guarantor being unable to meet their obligations;
- consider hardship requests;
- assess whether to securitise loans and to arrange the securitisation of loans
How long do you keep your information?
We are required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act, for example.
We are required to keep your information for 7 years from the closure of accounts, or otherwise as required for our business operations or by applicable laws.
We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.
Who do we share your personal information with?
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing Your Information
We may use and share your information with other organisations for any purpose described above.
Sharing with your representatives and referees
We may share your information with:
- credit reporting bodies or other approved third parties who are authorised to assess the validity of identification information;
- fraud reporting agencies;
- service providers that assist with fraud detection and prevention;
- organisations involved in surveying or registering a security property or which otherwise have an interest in such property;
- rating agencies to the extent necessary to allow the rating of particular investments;
- any party involved in securitising your facility, including the Reserve Bank of Australia (sometimes this information is de-identified), re-insurers and underwriters, loan servicers, trust managers, trustees and security trustees;
- businesses assisting us with funding for loans,
- service providers that maintain, review and develop our business systems, procedures and technology infrastructure;
- payment systems organisations including merchants, payment organisations that produce cards, cheque books or statements;
- our joint venture partners;
- organisations that assist with product planning, research and development;
- government or regulatory bodies;
- your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents);
- any of our associates, related entities or contractors;
- mortgage intermediaries, brokers, trade insurers;
- guarantors, referees (such as your employer, to verify information you have provided);
- advisors, auditors, agents, accountants, lawyers, solicitors; financial planners, insurers;
- tribunals or courts, government bodies, external dispute resolution bodies and in any instances where we are required by law.
How do you access your personal information?
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases, we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
How to access your credit eligibility information
Where you request access to credit information about you that we’ve got from credit reporting bodies, we will
- provide you access to the information within 30 days (unless unusual circumstances apply);
- ask you to check with the credit reporting bodies what information they hold about you. If we cant give you access, we will tell you why in writing.
How do you correct your personal information?
How we correct your information
Contact us if you think there is something wrong with the information we hold about you. We’ll try to correct it if it’s:
- irrelevant; or
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
What additional things do we have to do to correct your credit information?
If you ask us to correct credit information, we will help you with this in the following way.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So that we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
How do you make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by using the details below:
Attn: Privacy Officer
Address: Level 21/101 Grafton St, Bondi Junction, Sydney NSW 2022
Phone: 02 8316 6444
We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
Need more help?
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:
- Online: www.oaic.gov.au/privacy
- Phone: 1300 363 992
- Email: firstname.lastname@example.org
- Fax: +61 2 9284 9666
- Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
What additional things do we have to do to manage your complaints about credit information?
If your complaint relates to how we handled your access and correction requests. You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to credit information If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days. If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter.
If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Contact Details for Credit Reporting Bodies
- Equifax Australia Information Services and Solutions Pty Ltd
- Mail: Equifax Public Access, PO Box 964, North Sydney NSW 2059
You can take steps to protect your credit information. If you believe you may have been, or are likely to be a victim of fraud, you may request a credit reporting body not to use or disclose any credit information they hold about you. The credit reporting body must not use or disclose your information during the initial 21 days without your consent. If, after the initial 21-day period, the credit reporting body believes on reasonable grounds that you are likely to continue to be a victim of fraud, they may choose to extend this period. The credit reporting body must provide you with a written notice of the extension.
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
You can contact us by using the details below:
- Attn: Privacy Officer
- Address: Level 21/101 Grafton St, Bondi Junction, Sydney NSW 2022
- Phone: 02 8316 6444
- Email: email@example.com
What if you want to interact with us anonymously or use a pseudonym?
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way, however, as we are often governed by regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
- it is impracticable; or
- we are required or authorised by law or a court/tribunal order to deal with you personally.
What do we do with government-related identifiers?
In certain circumstances we may be required to collect documents which contain governmentrelated identifiers, such as your tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change from time to time. We will let you know of any changes to this Policy by updates on our website, or you may contact us for a copy of the most up to date policy at any time.