Privacy and Credit Reporting Policy

V17.1.2024

Introduction

Credit24 is a registered trademark and business name of IPF Digital Australia Pty Ltd (ACN 130 894 405) (Australian Credit Licence 422839) (‘we’ or ‘us’).

We abide by the Privacy Act 1988 (Cth) (Privacy Act); the Australian Privacy Principles (APPs) in Schedule 1 of the Privacy Act; and the Credit Reporting Code.

This Privacy and Credit Reporting Code informs you how we collect, use and protect your personal information.

The Australian Privacy Principles (APP) are available on the website of the Office of the Australian Information Commissioner.

This Privacy and Credit Reporting Policy applies to you if you create an account with Credit24, because in creating an account you will need to confirm that you have read and agree to the terms of this Privacy and Credit Reporting Policy.

  1. Why we collect personal information

First, to verify your identity and prevent fraud.

Secondly, to communicate with you. It is important that we can contact you if we need to. We may use telephone, direct mail, electronic direct mail or sms text messaging or other electronic messaging services so we can obtain information needed for your loan application and processing, assessing and administering your loan. We may also need to contact you through telephone, direct mail or through electronic communications to give you documents, notices and to notify you about details of your loan contract.

Thirdly, to process and assess your loan applications and to manage your loan account in compliance with regulatory requirements. This can include:

  • making enquiries and verifications about you and your financial circumstances;
  • obtaining a credit report about you from a credit reporting body;
  • making inquiries about the purpose and objectives for the loan you are seeking;
  • sharing credit information about you with credit reporting bodies;
  • deciding whether a loan is not unsuitable for you;
  • contacting your employer about your employment and related matters;
  • establishing and administering your loan account, including charging and billing;
  • complying with legal requirements and regulation; for example Anti-Money Laundering and Counter-Terrorism Act 2006 (Cth), Privacy Act and the National Consumer Credit Protection Act 2009 (Cth) and ASIC Regulatory Guide 209 – Credit Licensing: Responsible lending conduct;
  • Reporting suspicious matters to AUSTRAC to combat criminal activity; and managing our rights and obligations.
  1. How we collect your personal information

Wherever possible, we will collect personal information directly from you either through the internet, mail, telephone, electronic direct mail or in person. This information will generally come from what you have provided in your loan application and supporting documentation, for example, your financial or employment details.

We may collect personal information about you from third parties, such as any referees provided by you and third party service providers including credit reporting bodies. We hold your personal information in computer systems, electronic form, digital records, telephone recordings and/or paper files.

  1. What is personal information

Personal Information is information or an opinion about an individual who is identified or their identity can be reasonably ascertained from that information or opinion.

We collect personal information that includes, but is not limited to:

  • full name;
  • date of birth;
    gender;
  • Driver’s licence, Medicare & Passport details;
  • personal information to verify Visa details (where applicable);
  • current and previous addresses (including postal address);
  • contact details including telephone numbers;
  • e-mail addresses;
  • occupation and employer name;
  • cost of living, fixed and financial expenses and commitments;
  • bank account details;
  • consumer credit and identity verification reports;
  • name and contact details of applicant referees.
  • An individual’s credit history shared with a credit reporting body (details of the credit reporting bodies with whom we share information are listed below in 4. Notifiable Matters and Credit Reporting)
  1. Notifiable matters and credit reporting

We are required by law to advise you of ‘notifiable matters’ in relation to how we may use your credit information.

We may exchange your credit information with credit reporting bodies.

In order to obtain credit information about you from Credit Reporting Bodies (CRBs) we may be required to disclose the credit information about you which we hold. Those credit reporting bodies may then include that credit information about you in reports they provide to other credit providers.

Credit24 participates in Comprehensive Credit Reporting
New laws have enabled more information to be included in the information exchanged between credit providers and credit reporting bodies. This is called Comprehensive Credit Reporting (CCR).

How can this benefit you?
Previously the only credit information about you shared with a Credit Reporting Body was negative information like defaults. CCR shares positive information about you, such as repayments that you make on time. This approach gives a fairer and more accurate picture of your credit worthiness and supports responsible lending. This improved credit related information about you may be reflected in credit reports.

The credit information that is shared excludes your financial information. It does, however, includes the following:

    • information about your credit application; and
    • any application you make to us as an enquiry (‘a credit enquiry’); and
    • if you fail to meet your repayment obligations in relation to consumer credit provided by us under your consumer credit contract, for example as a result of an overdue payment (‘missed payment’); and
    • when your arrears are or exceed a specified payment amount or time frame as set out by legislation or guidelines; and
    • a payment default information for the arrears or the full amount due if we chose to accelerate the debt; and
    • the maximum amount of credit approved; and
    • type of loan account; and
    • date account was opened and, if applicable, closed date; and
    • if it was a secured loan or unsecured loan; and
    • if it was a sole or joint loan; and
    • other specific terms and conditions of the account; and
    • if you commit a serious credit infringement in relation to consumer credit provided by us under your consumer credit contract.

Reporting hardship

Included in the repayment history information about you which we will provide to the above Credit Reporting Bodies will be information about any payment arrangements or contract variations we enter into with you because you have notified us that you are in hardship and require temporary hardship relief from the payments required by your consumer credit contract with us. We will report to these Credit Reporting Bodies:

(i) that you have asked us for temporary relief from repayments because you are in hardship;
(ii) that we have accepted that you are in hardship and have agreed to vary the payments you are required to make under your consumer credit contract with us;
(iii) your payment history information under the varied payment arrangements; and
(iv) when the varied payment arrangement ends whether that is because it has been completed or because you have failed to make the payments required under the varied arrangement.

If you fail to make the payments required under the varied arrangement, this will be reported as part of your payment history information and may lead to us reporting to a credit reporting body that you are in default of your consumer credit contract with us.

We will NOT provide to any credit reporting body the reasons for your hardship and will continue to deal with that information as sensitive personal information under our Hardship Privacy Policy.

The credit reporting bodies to which we may disclose your credit information are:

Equifax Pty Ltd    Website: www.equifax.com.au

Illion                    Website: www.illion.com.au

Experian              Website: www.experian.com.au

If we provide information about your credit application to a credit reporting body, this may affect decisions by other credit providers as to whether they provide credit to you and on what terms.

If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement, then we may disclose this information to a Credit Reporting Body.

Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the Credit Reporting Body at any time to request that your credit information is not used in this way for direct marketing.

You may contact the Credit Reporting Body to advise them that you believe on reasonable grounds that you may have been, or are likely to be a victim of fraud. For a period of 21 days after the Credit Reporting Body receives your notification, the Credit Reporting Body must not use or disclose that credit information in the credit report.

You can contact any of the Credit Reporting Bodies for more information.
You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information and to make a complaint to us.

When creating a customer account we will share information with a Credit Reporting Body for the purpose of verifying your identity.

In the course of applying for a loan, we will obtain a credit report on you from a Credit Reporting Body and this may occur at any time after you commence the online application process. The enquiry will be listed in your credit file maintained by a Credit Reporting Body.

  1. When we disclose (share) personal information

5.1 Overseas

We may need to disclose your information, including information we receive through the credit reporting system, to organisations located overseas. For the most part, these service providers are related entities of IPF Digital Australia Pty Limited being other entities in the International Personal Finance plc (“IPF“) group of companies which perform a range of technology, operational and customer service functions for IPF Digital Australia.

IPF utilises cloud based data centres located in the United Kingdom,Ireland and Germany.

IPF Digital Australia also utilises a service provider that is located in Canada to assist us with customer enquiries via the webchat. The data that is collected through this tool may be transferred to, and or stored in Canada and the United States of America for the purpose of servicing the customer.

5.2 Australia

We may need to disclose your information, including information we receive through the credit reporting system to external service providers to us, such as:

  • Credit Reporting Bodies and their third party service providers, that we use to verify your identity and to obtain a credit report about you;
  • Identification services including DnB Green ID and Veda ID Matrix that aggregate identification sources including but not limited to:
    • Australian Electoral Roll;
    • Credit Bureaus;
    • Electronic White Pages;
    • Insurance Reference Service;
    • National Tenancy Database;
    • Driver Licence Registries (ACT/NSW/NT/QLD/SA/TAS/VIC/WA);
    • Australian Passport;
    • Accuity sanction screening service;
    • Velocity screening service;
    • Document verification service;
    • Visa verification service; and
    • Biometric ID verification service.
  • payment systems operators;
  • mailing houses;
  • telephone contact centres;
  • debt collection organisations; and
  • research consultants and professional advisors such as accountants, lawyers, auditors and if required by law, to government and regulatory authorities, for example, the Australian Tax Office.

We may also be required or permitted by law, to disclose personal information that we hold, including The Anti-Money Laundering and Counter-Terrorism Funding Act 2006 and the National Consumer Credit Protection Act 2009 and the Privacy (Credit Reporting) Code.

5.3 Privacy of disclosed information

We will take reasonable steps to ensure that these organisations are bound by sufficient confidentiality and privacy obligations with respect to the protection of your personal information.

IPF Digital Australia Pty Ltd reasonably believes that any of the related companies in the IPF group located outside of Australia that may have access to your personal information and the cloud based data centres that the IPF Group utilizes located in the UK, Germany and Ireland, are subject to a law, that has the effect of protecting the information in a way that is substantially similar to the way the APPs protect the information and that mechanisms can be accessed by the consumer to enforce that protection of the law.

In the event that your personal information is disclosed to a related company or service provider located in a jurisdiction that is not subject to privacy obligations equivalent to those that apply to us in Australia, and if the overseas recipient handles the personal information in breach of the APPs:

  • we will not be accountable under the Privacy Act; and
  • the individual will not be able to seek redress under the Privacy Act.

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.

  1. Sensitive information

Where it is necessary to do so, for instance, if you experience financial hardship, we may collect personal information about you that is sensitive. This includes information about your health, your religious beliefs, your political affiliations, or your criminal history. If you or third parties provide us with sensitive information, we will only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law. Where practical and reasonable, we will only collect sensitive information with your consent. However, if the information relates directly to your ability to meet financial obligations that you owe to us, you are treated as having consented to its collection.

  1. Government identifiers

IPF Digital Australia Pty Ltd may use Government related identifiers of an individual (for example: Passport, Driver’s Licence, Medicare Card, etc) where it is reasonably necessary for the Company to verify the identify the individual.

We do not use Government related identifiers of individuals as our identifier of you or of your loan or loan account.

  1. Security of personal information

We take all reasonable steps to ensure that your personal information is protected from:

  • unauthorised access, disclosure or modification;
  • misuse; and
  • loss.

When we no longer require your personal information (including when we are no longer required by law to keep records relating to you), we ensure that it is destroyed or de-identified.

  1. Website

Any time that you enter our website, we may record the date and time that you have done so, as well as any information that you have downloaded. Please refer to the Website Terms of Use to see how and why we record this information. We do not guarantee that the information that you send over the internet is secure. Please see the Website Terms of Use for more information.

  1. Your Access to the personal information we hold about You

You are generally entitled to access the personal information that we hold about you. You may contact our Customer Care on 1300 293 000 or info@credit24.com.au .We will deal with your request for such access within a reasonable time. If we refuse access, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. We may recover reasonable costs in relation to a request for access to personal information.

  1. Accuracy

We will take all reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. However, if your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Customer Care on 1300 293 000 or letstalk@credit24.com.au. If you establish that the personal information we hold about you is not accurate, complete and up to date, we will take reasonable steps to correct the information. If we cannot take reasonable steps to correct the information, because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide our services to you. In these cases, we will provide reasons for denial of correction.

  1. Direct Marketing

By accepting the terms of this Privacy and Credit Reporting Policy, you consent to the following unless you opt out.

  • From time to time, we may use your personal information other than sensitive information and your location, to provide you with information about our products and services, and those of third parties, that we consider may be of interest to you. We may contact you through telephone, direct mail, electronic direct mail, SMS text messaging or other electronic services.
  • We may also provide your details to other organisations for specific marketing purposes.
  • If your application is unsuccessful IPF Digital may assist you to obtain finance by offering your application to other credit providers.
  • We may use information that we hold about you for the purpose of preventing Small Amount Credit Contract (SACC) communications being sent to you in breach of Section 133CF of the Consumer Credit Protection Act 2009.

You can opt out of receiving direct marketing at any time if you no longer wish to receive marketing information. You can make this request to opt out by contacting us at 1300 293 000 or by ‘unsubscribing’ from the mail, email marketing or SMS text messages or other electronic messaging services you received from us.

  1. Questions and Complaints

If you have any questions or concerns about this Privacy and Credit Reporting Policy, or our use of your personal information, you can contact our Customer Care on 1300 293 000 or letstalk@credit24.com.au.

If you believe that the privacy of your personal information has been compromised or is not adequately protected contact our Dispute Resolution on 1300 293 000 or letstalk@credit24.com.au Once a complaint has been lodged, Dispute Resolution will respond to you as soon as possible.

Further information is available from the Office of the Australian Information Commissioner’s website at www.oaic.gov.au or contact the Information Commissioner’s hotline on 1300 363 992.

  1. Changes to the Privacy Policy.

We may make changes to this Privacy Policy from time to time (without notice to you) that are necessary for our business requirements or the law. We encourage you to visit our website – www.credit24.com.au from time to time to ensure that you have read our most current Privacy and Credit Reporting Policy.

  1. Your Consents

By agreeing to this Privacy and Credit Reporting Policy, you consent to the following:

  • Confirm that you are authorised to provide to us the personal information you will provide and confirm that you are the person making the application. This consent is required for us to verify your government issued document details with the issuer or official record holder;
  • Consent to us disclosing your personal information to a Credit Reporting Body and your government issued document details verified with the issuer or official record holder for identity checking requirements. This consent is to protect against identity fraud and without this consent we may not be able to consider or approve your application.
  • Consent to us collecting, using and disclosing personal information about you to enable IPF Digital Australia Pty Ltd to assess your application and to manage your loan account, including consent to disclose information to related companies and to third party service providers, both in Australia and outside of Australia. Without this consent we may not be able to consider or approve your application. See section 11 about how you can update and correct information we hold about you.
  • Consent to use your personal information for direct marketing as described in section 12. See section 12 for how you can opt out.
  • Consent to us disclosing whatever of your personal information we consider is necessary, for the purpose of credit reporting to a Credit Reporting Body. This disclosure of information is necessary for the integrity of the credit reporting system.

This Privacy and Credit Reporting Policy (V17.01.2024) is effective from 17.01.2024.