Alex Bank Pty Ltd ABN 13 627 244 848, Australian Financial Services and Australian Credit Licence 510 805 (Alex, we, us or our), recognises that your privacy is very important and we are committed to protecting the personal information we collect from you. The Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles and registered privacy codes (including the Privacy (Credit Reporting) Code 2014 (Code)) govern how we must manage your personal information.
This Credit Reporting Policy sets out how we collect, use, disclose and otherwise manage credit-related personal information.
What is credit information?
Credit information is personal information that has a bearing on credit that has been provided to you or that you have applied for. This includes credit for personal, domestic or household purposes and credit in connection with a business. It can also cover information about you as a guarantor of a loan or as an insured party under a credit-related insurance policy.
What kinds of credit information do we collect and hold, and how do we collect it?
If you apply for credit from us (in the form of us allowing you to defer payment of a debt owed to us on certain terms), or give a guarantee, we may ask for, collect and hold various information related to you.
We also collect and use all types of ‘credit information’, ‘credit eligibility information’ and ‘CP–derived information’ (as those terms are defined in the Privacy Act).
‘Credit information’ is the information we may collect and give to a credit reporting body (CRB). The CRB’s we deal with are:
- Equifax – www.equifax.com.au
- illion – www.illion.com.au
- Experian – www.experian.com.au
For contact details and information on how credit reporting bodies manage credit related personal information, please see their privacy policies available at the links above.
Sometimes we collect information about you from other people. For example, CRBs and other lenders.
Information we may collect about you
The information we collect or hold includes:
- identity details;
- basic information about your credit account (for example when it was opened);
- payments information;
- details about information requests we or other credit providers make about you to a CRB;
- financial hardship information;
- information about certain overdue payments and about serious credit infringements and information about payments or subsequent arrangements in relation to either of these;
- various publicly available information like bankruptcy, insolvency and credit-related court judgements;
- the fact that you have applied for services from us; and
- the fact that we are a credit provider to you.
‘Credit eligibility information’ is the information CRBs give to us. This information relates primarily to your dealings with other credit providers (for example, banks, other financial institutions, or other organisations that may provide you with credit in connection with their products or services). It may also include certain credit worthiness information that we derive from the data that we receive from a CRB. Sometimes we may also collect credit eligibility information about you from other credit providers. The information we can receive from a CRB has been extended as part of our comprehensive credit reporting (see below).
‘CP-derived information’ means any personal information that is derived from information given to us by CRBs and that has bearing on your credit worthiness. This could be, for example, a credit score.
In this policy, we refer to ‘credit-related information’ to capture some or all information referred to above (as the context requires).
For what purposes do we collect, hold, use and disclose credit information?
The main reason we collect, use, hold and disclose credit information is to provide you with products and services. This includes:
- checking whether you are eligible for the product or service;
- providing the product or service;
- helping to manage the product or service; and
- checking your identity.
We use information from credit reporting bodies to confirm your identity, assess application for credit, manage our relationship with you and collect overdue payments. We may also use this information as part of arriving at our own internal assessment of your creditworthiness.
If you are offering to act as guarantor your credit information may be necessary to assess whether the borrower will be eligible for a loan if you act as guarantor.
We may also use your credit information for other purposes. For instance, to comply with legislative or regulatory requirements in any jurisdiction, to prevent fraud, crime or other activity that may cause harm in relation to our products or services, and to help us run our business. We may also use your credit information to tell you about products or services we think may interest you, subject to legal restrictions on using this type of information for marketing purposes.
How do we hold credit information?
Much of the information we hold about you will be stored electronically in secure data centres located in Australia. Some information we hold about you will be stored in paper files. We use a range of physical and electronic security measures, such as locks and passwords, to protect the security of the credit information we hold. We also train our employees to keep information secure.
Who do we disclose your credit information to, and why?
The way we approve and manage credit involves a range of tasks. Some of these tasks are carried out for us by third party service providers, both in and outside Australia, including in India and the Philippines. In carrying out these tasks, service providers may have access to credit related personal information.
To protect your credit information, Alex enters into contracts with the service providers that require them to comply with the Privacy Act. These contracts oblige them to only use the credit information we disclose to them for the specific role we ask them to perform.
We may exchange your credit information with CRBs. When we exchange your credit information with CRBs, this information is used to validate your identity, to assess your credit application, and in managing your account with us.
When you submit an application for a product with Alex, we may obtain a credit report on you from a CRB and this may occur at any time after you commence your online application. The enquiry will be listed in your credit file that is maintained by the relevant credit reporting body.
Generally, we disclose credit information to organisations that help us with our business. These may include:
- our agents, contractors and external service providers (for example, mailing houses and technology service providers);
- credit representatives who sell products and services on our behalf;
- other organisations, who jointly with us, provide products or services to you;
- other financial services organisations, including banks, superannuation funds, stockbrokers, custodians, funds managers and portfolio service providers;
- organisations involved in our funding of loans (including securitisation trustees, investors and their advisers);
- credit reporting bodies;
- organisations that provide us with insurance to cover our lending risks;
- Alex’s financial advisers, legal advisers or auditors;
- your representatives (including your legal adviser, financial adviser, broker, executor, administrator, guardian, trustee, or attorney);
- government agencies or dispute resolution schemes that assist consumers in relation to credit; and
- where permitted by law, debt collection agencies or other lenders, such as where you have given mortgage security over the same property to us and another lender.
We may also disclose your credit information to others outside Alex where:
- we are required or authorised by law to do so;
- you have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
- we are otherwise permitted to disclose the information under the Privacy Act.
As permitted under the Privacy Act, we may participate in repayment history reporting as part of our ‘comprehensive credit reporting’. When we receive a loan application, we may get information about whether the applicant has a history of making required repayments on time and whether any have been made after they are due.
For all borrowers, we may periodically report the same information to CRBs. As part of our comprehensive credit reporting we may also disclose the date an account is opened and closed, credit limits and the type of credit. Such information may also be provided by a CRB. For more information about comprehensive credit reporting, please visit creditsmart.org.au .
If you’re having trouble making your repayments, we can help. Please contact email@example.com for a confidential conversation about your situation.
Access to and correction of credit information
You can request access to credit information we hold about you. You can also ask us to correct any inaccurate information we hold or have provided to others. To do so, please contact us with an explanation and materials outlining the inaccuracy.
There is no fee for requesting that your credit information is corrected or for us to make corrections. In processing your request for access to your credit information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.
There are some circumstances in which we are not required to give you access to your credit information or certain types of credit information requested by you.
If we refuse to give you access to or to correct your credit information we will give you a notice explaining our reasons, except where it would be unreasonable to do so.
If we refuse your request to correct your credit information, you also have the right to request that a statement be associated with your credit information noting that you disagree with its accuracy.
If we refuse your request to access or correct your credit information, we will also provide you with information on how you can complain about the refusal.
Resolving your credit information concerns and complaints – your rights
If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us.
We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.
We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five business days but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.
If you are unhappy with our response, there are other bodies you can go to.
The Australian Financial Complaints Authority (AFCA) can consider most privacy complaints involving providers of financial services.
AFCA can be contacted at:
Australian Financial Complaints Authority
GPO Box 3 Melbourne VIC 3001
Phone: 1800 931 678
Under the Privacy Act you may complain to the Oﬀice of the Australian Information Commissioner about the way we handle your personal information.
The Commissioner can be contacted at:
GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992
If you would like more information about how we protect your privacy, please contact us using the details below:
Email – you can email us at firstname.lastname@example.org; or
Phone – you can call us on 13 ALEX.
Changes to the Credit Reporting Policy
We may change the way we handle credit information from time to time for any reason. If we do so, we will update this Credit Reporting Policy. An up-to-date version is available on www.alex.bank