Credit Reporting Policy
This Credit Reporting policy contains important information about your credit information and credit eligibility information (“credit related information“).
About this policy
This information applies to IPF Digital Pty Ltd ACN 130 894 405 trading under the name Credit24.
At Credit24 we take our obligations to protect personal information about individuals, including credit information and credit eligibility information, seriously. We are bound by Part IIIA of the Privacy Act 1988 (Cth) (“Privacy Act“) and the Privacy (Credit Reporting) Code 2014 (Version 1.2) (“Credit Reporting Code“), which govern credit reporting in Australia.
Our aim is to comply at all times with the credit reporting and privacy laws that apply to us. If you have a comment, query or complaint regarding a privacy matter, we encourage you to discuss it with us.
What kinds of credit information do we collect and hold?
At Credit24, we collect and hold your credit related information, examples of which include:
Identification information, such as your name, address, date of birth or employer.
Details of consumer credit that you have applied for, the type and amount of that credit and the fact that an information request has been made about you. An information request is when we ask a credit reporting body to provide us with credit reporting information about you. The type of credit and the amount of credit sought in an application for credit made by you in connection with which we made an information request.
Consumer credit liability information. This is information about consumer credit accounts you hold, or have held, with us, such as the type of account, the date the account was opened and closed, the maximum amount of credit approved for that account and some specific terms and conditions relating to the repayment of credit under that account.
Repayment history information. For consumer credit accounts you hold, or have held, this includes whether or not you made any payment that was due in a particular month, and where a payment was overdue, when it was ultimately paid.
Default information about you. This is information about a payment owed by you as a borrower in connection with consumer credit that remains overdue for more than 60 days and which we can disclose to a credit reporting body if certain requirements under the Privacy Act are met.
Payment information about you. Payment information is a statement that an overdue payment in relation to which default information was provided to a credit reporting body has been paid.
New arrangement information about you. This is information about you having entered into certain types of arrangements with us in relation to consumer credit where you have been overdue in making a payment and we have provided default information to a credit reporting body. New arrangement information is either that the terms or conditions of that consumer credit have been varied as a result of you being overdue or that you have been provided with new credit relating to the original amount of credit.
Court proceedings information about you. This is information about a judgment of an Australian court that is made against you that relates to credit that was provided to, or applied for, by you.
Personal insolvency information about you. This is information recorded in the National Personal Insolvency Index and relating to your bankruptcy, a debt agreement proposal given by you, a debt agreement made by you, a personal insolvency agreement executed by you, a direction given, or an order made, under the Bankruptcy Act that relates to your property or an authority signed under the Bankruptcy Act that relates to your property.
Publicly available information about you:
- that relates to your activities in Australia or the external territories and your credit worthiness; and
- that is not court proceedings information about you or information about you that is entered or recorded in the National Personal Insolvency Index.
An opinion we have on reasonable grounds that you have committed a serious credit infringement in relation to consumer credit that was provided to you. A serious credit infringement includes, in summary:
- that you were fraudulently obtaining (or attempting to obtain) consumer credit; or
- that you are fraudulently evading (or attempting to evade) your consumer credit obligations; or
- that you are no longer intending to comply with your consumer credit obligations as we have not been able to contact you for 6 months in accordance with the Privacy Act.
- Scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us or by credit reporting bodies wholly or partly on the basis of the information above.
How we collect your credit-related information
We collect credit information in a variety of ways, such as obtaining the relevant information directly from you or by persons acting on your behalf (including on application forms or other forms or in our ongoing dealings with you in connection with credit). Some credit information will also be derived by us from your transactions in connection with credit, such as when you make payments to us.
We also collect credit-related information from credit reporting bodies.
Exchanges of information about you with credit reporting bodies
We may disclose your credit information to obtain credit reporting information about you from credit reporting bodies. Credit reporting information includes:
- credit information of the kinds listed under ‘What kinds of credit information do we collect and hold?’ but relating primarily to your dealings with other credit providers (such as about credit applications you have made or credit that you hold with other credit providers). This information will typically have been provided by other credit providers or other third parties; and
- credit worthiness information about you that credit reporting bodies derive from the information above, such as credit scores, risk ratings and other evaluations about you.
We may also disclose your credit information relating to your dealings with us to credit reporting bodies. Those credit reporting bodies may include that information in reports that they provide to other credit providers to assist them to assess your credit worthiness. For example, we will provide information that identifies you and about your application for credit when obtaining credit reporting information for the purposes of assessing that application.
We may also exchange your credit information with credit reporting bodies for the purposes of verifying your identity.
Should you fail to meet your payment obligations to us or commit a serious credit infringement in relation to credit provided by us, we may be entitled to disclose this information to credit reporting bodies. Credit24 obtains credit worthiness information and discloses credit information to the following credit reporting bodies:
Veda Applied Intelligence (Veda)
Postal address: PO Box 964, North Sydney, NSW 2059
DBCC Pty Ltd (D&B)
Postal address: 479 St Kilda Rd, Melbourne, Vic 3004
Both Veda and D&B are required to have a policy which explains how they will manage your credit-related personal information. If you would like to read the policies of these credit reporting bodies please visit their websites and follow the “Privacy” links, or you can contact them directly for further information. You have the right to request these credit reporting bodies to exclude your credit reporting information from any permissible direct marketing activities Credit24 may request them to perform.
You also have the right to request credit reporting bodies not to use or disclose your credit reporting information if you believe that you have been, or are likely to be, the victim of fraud (for example, you suspect someone is using your identity details to apply for credit). You must contact the credit reporting bodies directly should this be the case.
What kinds of credit worthiness information do we derive from
credit reporting information?
We utilise credit reporting information obtained from credit reporting bodies to derive other information that assists us in assessing your creditworthiness, for example, credit risk ratings and credit scores.
How do we hold and protect credit information and credit eligibility information?
We, and service providers on our behalf, may hold your credit related information in computer systems, electronic form, digital records, telephone recordings and/or paper files.
We understand the importance of protecting personal information, including credit information and credit eligibility information, we hold. We take steps to ensure that this information is free from misuse, interference, loss, unauthorised access or modification. This includes:
- securing information both in physical and electronic form;
- having internal procedures and measures limiting access to personal
- information only to those that need access for their legitimate activities; and
- protecting our systems by appropriate technology solutions.
We may hold your personal information in servers in Estonia, Latvia, Lithuania, Finland, the Czech Republic and the United Kingdom.
For what purposes do we collect, hold, use and disclose credit information and credit eligibility information?
Credit24, holds, uses and discloses credit information and credit eligibility information about you for purposes reasonably necessary for our business activities and consistently with the requirements in the Privacy Act as permitted by law. These purposes include:
- to make credit enquiries;
- to carry out identification verification procedures;
- to assess applications for credit;
- for the ongoing servicing and administration of our accounts and products;
- to assist with the management, including recovery, of outstanding debts;
- to assist you if we consider that you may be at risk of default;
- internal management purposes including for data analysis;
- to participate in the credit reporting system and provide information to credit reporting bodies as permitted by the Privacy Act;
- to deal with complaints and legal proceedings;
- to meet our legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies when authorised or required by law); and
- to assist other credit providers with such purposes in circumstances permitted by the Privacy Act (such as disclosing information to another credit provider with your consent or where you have committed a serious credit infringement).
Restrictions apply under the Privacy Act in relation to the circumstances and purposes for which such information may be used or disclosed and we comply with these restrictions. For example, credit eligibility information may not be disclosed to some types of overseas entities and restrictions apply on the use of credit eligibility information for direct marketing.
Will we be disclosing your credit information or credit eligibility information to overseas organisations?
We may disclose personal information about you, as appropriate, to our related bodies corporate or their agents, including those that may be overseas in Estonia, Latvia, Lithuania, Finland, the Czech Republic or the United Kingdom, assignees, agents, contractors, external advisors, or organisations for verifying your identity and managing and improving our product offer.
If you are a politically exposed person we may validate your status by disclosing your personal information to service providers in Australia and the United States of America.
We may hold your personal information in servers in Estonia, Latvia, Lithuania, Finland, the Czech Republic and the United Kingdom.
How can you access credit eligibility information we hold about you?
You are generally entitled to access the credit information that we hold about you (in a manner you request, if this is reasonable and practicable). You may contact the Privacy Officer on FREECALL 1800 091 967 or firstname.lastname@example.org. We will need to verify your identity before giving you access. We will usually provide the information requested within 30 days of receiving your request. If there is a reason we are unable to agree to a request for access to your credit eligibility information we will advise you of this in writing. There is no charge to make a request for access request but we may apply an administration fee for providing access in accordance with your request.
How can you seek correction of the credit information or credit eligibility information about you which we hold?
We aim to hold accurate and up-to-date credit information and credit eligibility information about you at all times. If you consider that any such information we hold about you is incorrect in any way, you may seek the correction of that information. To seek such a correction please call the relevant contact number provided above to discuss your query. In certain situations, we may not agree to a request to correct information we hold about you. If this occurs we will advise you of this and our reason for not agreeing to the correction request in writing.
How can you make a complaint about our compliance with our credit reporting obligations and how will we deal with such a complaint?
If you believe that we have failed to comply with the credit reporting requirements in Part IIIA of the Privacy Act or the Credit Reporting Code, please contact us and we will then follow our Internal Dispute Resolution process. Please do not hesitate to let us know if you have a complaint. You
must specify the nature of the complaint.
You will receive an acknowledgment of your complaint after we receive it. We will investigate all complaints and aim to resolve them as soon as possible.
If we cannot resolve your complaint within this period we will notify you as to the reasons why. You may refer the matter to External Dispute Resolution (contact details below) if you wish to complain about the delay.
We will give you a written notice of our decision.
If the complaint remains unresolved or you are unsatisfied with our decision you may complain to our External Dispute Resolution scheme (“EDR“). Credit and Investments Ombudsman (CIO), via the following channels:
Phone: 1800 138 422 Fax: (02) 9273 8440
Email: go to the CIO website http://www.cio.org.au/
Mail: Case Management Team
Credit and Investments Ombudsman Ltd
PO Box A252
South Sydney NSW 1235
CIO Membership No. M0016669
CIO independently and impartially resolves disputes between consumers and participating members on matters including privacy. You may also complain to the Office of the Australian Information Commissioner (the “OAIC“). The contact details for the OAIC are:
The Office of the Australian Information Commissioner
GPO Box 2999 Canberra ACT 2601 Australia
Phone: 1300 363 992 Fax: 02 9284 9666 Website: www.oaic.gov.au
Depending on the nature of the complaint, sometimes we will be required to notify a credit reporting body or credit provider of the making of the complaint and our decision.