Credit Reporting Policy
Personal Information vs Credit Information
Personal Information is details about an individual that can be used to identify that individual. The information the company collects may include, but is not limited to, an individual’s:
• Contact Details (such as residential and postal addresses, phone numbers, and email addresses)
• Date of Birth
• Account Details
• Marital Status (and other household information such as number and age of dependents)
• Occupation & Employment Information
• Financial Information (such as assets, liabilities, income and expenditure)
• Complaint Details
A subsection of personal information is referred to as credit information. These typically include, but are not limited to:
• Credit Liability Information
• Credit History
• Type and Amount of Credit
• Details of amounts payable and when such amounts are payable
• Repayment History (including when payments were made and whether payments were made when due)
• Default Information
• Credit Report File Number
Credit Reporting Information
A credit report contains information about an individual’s credit history and personal details. Often these are used by credit providers to assess an individual’s eligibility to obtain credit, verify their identity, or manage accounts held with a credit provider. Credit reporting bodies collect and exchange this information with credit & service providers.
The Privacy Act 1988 limits the information that credit providers can disclose to credit reporting bodies, as well as the ways in which credit providers can use credit reports.
Consent to Collect & Disclose Credit Reporting Information
One of the company’s roles is to act as a collection agent for its clients. Part of this role may involve handling Credit Information of individuals. Our clients, who are usually the original or assigned credit provider, provide consent for us to act on their behalf. By extension, any consent to collect/disclose credit information obtained at origination of the matter extends to our company as well.
Disclosure to Credit Reporting Bodies
The information the company can exchange with credit reporting bodies includes:
• Identification details
• Details of the specific debt(s) the company is handling
• Any pending payment default(s) the company has notified an individual about
• Whether an individual has committed a Serious Credit Infringement (such as fraud)
The company also asks credit reporting bodies to provide us with a copy of certain individuals credit reports to assist in our work of collecting overdue accounts.
There are four main credit reporting bodies operating in Australia. These are:
• Equifax – www.equifax.com.au
• Illion – www.illion.com.au
• Experian – www.experian.com.au
• Tasmanian Collection Service – www.tascol.com.au
Individuals can obtain a free copy of their credit reports held by the above bodies by visiting the respective websites.
Prior to sending information to credit reporting bodies for the purposes of default listing, the company ensures all required regulatory notices have been issued to the relevant individual by the credit provider. These will be sent to the last known email address where possible, or failing that, to the last known postal address. In addition to the regulatory notices, the company makes their own attempts to contact an individual.
How is Information Transferred and How is it Secured?
Transfer of information with Credit Reporting Bodies is done via two methods. One is a Secure File Transfer Protocol Server, and the other is directly through the relevant Credit Reporting Body’s secure online web portal. To ensure information security, only a limited number of CAPI licensed staff within the company have access to these, and access is revoked for staff who leave the company’s employment. If a staff member is terminated or otherwise leaves our employment, the company lodges a request with the Credit Reporting Body within 2 business days for their access to be revoked. The company also conducts regular User Access Reviews for both our internal systems and any SFTP Servers or online portals for credit reporting bodies.
If credit reporting information about an individual changes (such as an outstanding account being finalised) the company endeavours to update any relevant credit reporting bodies within 5 days. Should this not be possible, the information will be updated at the earliest possible opportunity.
Disclosure to Third Parties
The company will never disclose or discuss any credit reporting information about an individual to a third party without the express verbal or written consent of said individual.
What Do We Do With Credit Related Information?
The company uses information from credit reports obtained from credit reporting bodies to confirm individual’s identity, manage our relationship with individuals, and to assist in recovering overdue payments.
How Do We Hold Credit Reporting Information?
The company stores credit reports about individuals in a secure location with other information on those same individuals.
Anyone can request access to all information the company holds about them, request any incorrect information be corrected, or make a complaint to us about their credit related information.
Protecting Your Credit Information
The company is committed to ensuring the security of any credit information we handle. We store information both in hard copy and electronic form. The company protects credit information from misuse, loss, unauthorised access, modification and disclosure. The steps taken to protect personal information include, but are not limited to:
• Ensuring database security through password protection, as well as secure servers and data storage devices
• Staff training on confidentiality
The company retains secure electronic records on our premises and systems, or offsite using trusted third parties. For more detailed information on our security safeguards, please refer to our Information Security Policy.
Accuracy of Information
The company is constantly vigilant to ensure that any credit information we hold or report is as up-to-date and accurate as possible. The company will not use any information for credit reporting purposes unless we have been able to properly verify it is accurate.
There are some limitations, in that an individual may opt not to provide their current information. In a situation such as this, the company will always use the most recent information available when disclosing any matters to a credit reporting body.
Disclosure to Overseas Entities
The company does not disclose credit information to overseas entities.
The company does not engage in any Direct Marketing or related/similar activities, nor do we forward or disclose any personal or credit information held in our systems to any third parties for the purpose of Direct Marketing or related/similar activities.
Access to Credit Reporting Information
Individuals can contact the company to request access to credit information we hold about them. The company will provide access to the information and may ask individuals to check with credit reporting bodies as to what information those organisations hold to ensure information is accurate and complete.
Is there a fee?
There is no fee for making the initial request, however in some cases there may be an access charge to cover the time we spend locating, compiling, and explaining the information requested. The fee may consist of a flat “access charge” fee plus any photocopying costs or out-of-pocket expenses. If a fee is requested, it will need to be paid before the information is provided.
How long does it take to gain access to requested information?
The company aims to make requested information available within 30 days of a request, however in cases where large amounts of data are requested, or a lengthy review is involved additional time may be necessary.
Can the company deny or limit a request for access?
In certain circumstances, the company is allowed to deny an information request, or to limit access to requested information. Some cases where the company may refuse to provide access to an individual’s personal information include circumstances where:
• Providing access would have an unreasonable impact on the privacy of others
• The information relates to existing or anticipated legal proceedings and would not be discoverable in those proceedings
• Providing access would reveal our intentions in relation to negotiations with an individual in such a way as to prejudice those negotiations
• Providing access would be unlawful
• Denying access is otherwise required or authorised by law
• The request for access is frivolous or vexatious
In the event the company refuses to provide an individual with access to their personal information, we will provide an explanation for that refusal.
Correcting Incorrect Information
While the company maintains an automatic system for checking the validity of credit reporting on files in our system, all matters are subject to a manual check prior to any credit reporting activity taking place. Still, the company does recognise that on rare occasions, errors may happen. If an individual believes the credit reporting information the company holds on them is incorrect, they may request a correction to that information.
The individual should contact the company to discuss the perceived error, and if the company determines that the information is incorrect, or an error has taken place, we will endeavour to correct it and notify you in writing within 14 days. The company will also aim to update information which we discover to be incorrect on our own, even if the individual has not contacted us to notify of the issue.
There is no fee for an individual wishing to request a correction of credit reporting information they believe to be incorrect.
In some cases, the company may refuse to update credit reporting information on the advice of an individual. This may take place if the company holds or finds evidence that the correction requested by the individual is demonstrably false or incorrect. If you have requested a correction in writing and the company rejects this request, you will be notified in writing within 30 days.
Individuals with concerns relating to the accuracy of information on their credit file with a specific Credit Reporting Body may wish to contact them directly:
Equifax – www.equifax.com.au
Illion – www.illion.com.au
Experian – www.experian.com.au
Tasmanian Collection Service – www.tascol.com.au
If an individual believes, on reasonable grounds, that they have been a victim of fraud (including identity fraud) as it relates to a matter being handled by the company, they should inform the company of this immediately and undertake appropriate steps to initiate a fraud investigation with their local police. The company will assist the police with the investigation where possible (or else refer the matter to our client to assist), and if the outcome reflects that any matter(s) in our system are fraudulent, they will aim to correct any relevant credit information within 14 days. This includes both in the company’s system and with any Credit Reporting Bodies the information has been shared with.
Individuals wishing to obtain more details about the way the company manages their personal/credit information or wanting to access or seek correction of their personal/credit information may apply in writing to:
PO Box W245