Credit Information Management Policy

Privity Pty Ltd t/as Haircare Australia

Purpose and Application

1.1          Privity Pty Ltd (ABN 23 007 887 729) trading as Haircare Australia (Haircare Australia) is bound by the Privacy Act 1988 (Cth) (as amended from time to time) (Privacy Act) and the Credit Reporting Privacy Code (CR Code) in relation to the way that Haircare Australia handles credit information.  The Privacy Act and CR Code regulate the manner in which Haircare Australia can handle certain types of credit information and how Haircare Australia must respond to requests to access and correct credit information.

1.2          Haircare Australia views any breach of privacy protection as serious, and will take appropriate action in such cases.

1.3          This Policy sets out Haircare Australia's credit information handling procedures and the rights and obligations that both you and Haircare Australia have in relation to your credit information.

1.4          This Policy applies to the extent that Haircare Australia is a credit provider for the purposes of the Privacy Act.  Haircare Australia's general information privacy policy is available here.  Haircare Australia's Terms and Conditions are available here.

  1. What is credit information?

2.1          Credit information is personal information that is related to credit that you have applied for or which has been provided to you such as your contact details, information about your credit accounts, and any default and payment information.

2.2          Credit eligibility information includes the credit information listed above, as well as:

(a)           information disclosed to Haircare Australia by a credit reporting body; and

(b)           information Haircare Australia derives about you from conducting its own analysis of information reported back to Haircare Australia by a credit reporting body.

2.3          Credit reporting information is information derived by a credit reporting body from your credit information, which may include an assessment of your credit worthiness and your eligibility for consumer credit.

  1. What kinds of credit information does Haircare Australia collect and how does Haircare Australia collect it?

3.1          Specific kinds of credit information and credit eligibility information that Haircare Australia collects and holds may include:

(a)           your identification information, including your name, date of birth, drivers licence details, postal and residential addresses, telephone and facsimile numbers, and email addresses;

(b)           information about your financial circumstances required to assess applications for credit, for example, your income, your expenses, your savings and assets and liabilities;

(c)           information about credit you might have;

(d)           specific financial information, including various account details and superannuation details;

(e)           details of enquiries made about you by other credit providers or insurers;

(f)            details of new arrangements to vary or refinance other consumer credit;

(g)           opinions from other credit providers as to whether you have committed serious credit infringements;

(h)           details about your credit worthiness, for example, other credit you might have or have applied for, information relating to court proceedings, and details from the National Personal Insolvency Index; and

(i)            information about your repayment history, and whether you have had any overdue payments or defaults.

3.2          Haircare Australia collects credit information and credit eligibility information about you if you apply for credit or give a guarantee.  Haircare Australia may collect credit information from you if you provide it to Haircare Australia in person, or if you complete an Application for Credit Account.

3.3          In the course of operating its business, Haircare Australia may also collect credit information from third parties such as:

(a)           credit reporting bodies, for example, a credit report;

(b)           other credit providers, for example, opinions about your credit worthiness;

(c)           public registers or other publicly available sources of information;

(d)           your personal representatives, which may include other financial advisors, an administrator, or a solicitor; and

(e)           Haircare Australia's service providers, contractors, suppliers or business partners.

3.4          If you choose not to give Haircare Australia any credit information that it requests from you, Haircare Australia may not be able to approve your application for credit, or provide you with any goods or services you have asked it to supply.

  1. Purposes for which Haircare Australia collects, holds, uses and discloses credit information

4.1          Haircare Australia will generally collect, hold, use and disclose credit information and credit eligibility information for the following purposes:

(a)           assessing an application for credit and determining your eligibility for credit;

(b)           assessing whether to accept an individual as a guarantor;

(c)           ongoing management of your Credit Account, including, where relevant, by providing you notice to avoid defaulting on your obligations;

(d)           internal management purposes directly related to the provision or management of credit;

(e)           collecting payments that are overdue in relation to commercial credit;

(f)            informing you about products or services that Haircare Australia thinks may be of interest to you, subject to complying with legal restrictions on using credit information and credit eligibility information for marketing purposes;

(g)           participating in an external dispute resolution scheme;

(h)           assisting Haircare Australia to collect any overdue payments; and/or

(i)            investigating whether an individual has or has attempted to fraudulently evade obligations in relation to consumer credit.

4.2          By providing Haircare Australia with your credit information, or by requesting credit from Haircare Australia, you consent to Haircare Australia collecting, holding, using and disclosing your credit information and credit eligibility information for the above purposes.

4.3          You can opt out of receiving marketing materials from Haircare Australia by contacting Haircare Australia's Privacy Officer.  You may also opt out of your credit information being used by credit reporting bodies to pre-screen for direct marketing purposes.

4.4          Haircare Australia may also use or disclose credit information where Haircare Australia is authorised or required by law to do so.

4.5          The types of third parties to whom Haircare Australia may disclose your credit information and credit eligibility information include, but are not limited to:

(a)           Haircare Australia's related bodies corporate;

(b)           Haircare Australia's contractors and service providers, for example, persons who process applications for credit or manage the credit Haircare Australia provides, or technical or support services;

(c)           Haircare Australia's suppliers, for example, insurers;

(d)           professional advisors, for example, legal advisors;

(e)           representatives who sell Haircare Australia's products and services on its behalf;

(f)            other financial institutions, including credit providers;

(g)           other credit providers if Haircare Australia is acting as agent for that credit provider or otherwise, with your consent;

(h)           potential guarantors;

(i)            credit reporting bodies; and

(j)            debt collection agencies.

4.6          Haircare Australia holds all applicable types of credit information as physical records, records on Haircare Australia's servers, and in some cases, records on third party servers, which may be located overseas.

4.7          Haircare Australia takes active steps to hold all hard copy and electronic records of personal information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure.

4.8          Haircare Australia has procedures in place to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

  1. Notifications

5.1          When Haircare Australia collects credit information from you, it  will take reasonable steps to notify you or ensure that you are otherwise aware of:

(a)           the fact that Haircare Australia has collected your credit information, and whether that collection is required or authorised by law;

(b)           the purposes of collection;

(c)           the consequences if credit information is not collected (such as if this will affect Haircare Australia's ability to provide products or services to you);

(d)           the usual situations in which we disclose credit information of the kind collected;

(e)           information about this Policy, in particular how it contains information about accessing and correcting the credit eligibility information held by Haircare Australia, and Haircare Australia's complaint procedures; and

(f)            whether Haircare Australia is likely to disclose credit information or credit eligibility information to entities that do not have an Australian link, and the relevant countries in which such entities are located.

5.2          Some of the above information is included in this Policy.

  1. Cross border disclosures of information

6.1          As at the date of this Policy, Haircare Australia is not likely to disclose credit information or credit eligibility information to any overseas entities that do not have an Australian link.

6.2          If in future Haircare Australia proposes to disclose credit information or credit eligibility information to such entities, it will do so in compliance with the requirements of the Privacy Act.

  1. Credit Reporting Bodies

7.1          Haircare Australia may provide your credit information to, or collect your credit reporting information from, a credit reporting body.  As at the date of this Policy, thecredit reporting body that Haircare Australia deals with is Dun & Bradstreet. The contact details for Dun & Bradstreet are set out below:

Website:            http://dnb.com.au/Footer/Contact_Us/

Address:           Level 10, 431-439 King William Street, Adelaide SA 5000

Mail:                 PO Box 10012, Adelaide BC SA 5000
Telephone:        +61 8 7088 5155
Facsimile:         +61 8 7088 5166

7.2          Please note that the credit reporting body may include the information in reports provided to other credit providers to assist them to assess your credit worthiness.  Further, if you fail to meet your payment obligations in relation to consumer creditor you commit a serious credit infringement, Haircare Australia may be entitled to disclose this to the credit reporting body.

7.3          You are entitled to request directly from the credit reporting body:

(a)           the credit reporting body's credit information management policy;

(b)           that it not use your credit informationfor the purposes of pre-screening of direct marketing by another credit provider; and

(c)           that it not to use or disclose your credit information, if you believe on reasonable grounds that you have been, or is likely to be, a victim of fraud.

  1. How can you access and correct your information?

8.1          You have a right to request access to your credit information and credit eligibility information and to request its correction if it is out of date or incorrect.  You may do so at any time by sending a written request to Haircare Australia's Privacy Officer using the contact details set out at the end of this Policy.

8.2          You do not need to provide a reason for your request for access to your credit information and credit eligibility information.  Haircare Australia may charge a small fee for providing access to information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form.

8.3          Haircare Australia will respond to all requests for access to or correction of credit information and credit eligibility information within 30 days of the request.

8.4          Please note there may be circumstances in which Haircare Australia cannot provide you with access to your information, such as where the requested access will have an unreasonable impact upon the privacy of others or where Haircare Australia is required by law to withhold the information.  If Haircare Australia is unable to provide you with access to your information, or make the amendments which you have requested, Haircare Australia will provide you with reasons for this decision.

  1. Enquiries and complaints

9.1          If you have a question about this Policy or you believe that Haircare Australia has not complied with Part IIIA of the Privacy Act or the CR Code, please direct your concerns/query to Haircare Australia's Privacy Officer using the contact details set out at the end of this Policy.

9.2          Haircare Australia takes all complaints seriously.  Within 7 days of your complaint, Haircare Australia will provide you with a written notice acknowledging your complaint, and setting out how it will deal with your complaint.  Haircare Australia will make a final decision in respect of your complaint within 30 days from the date of your complaint, or as otherwise agreed with you.

9.3          If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Telephone:        1300 363 992

Email:   enquiries@oaic.gov.au

9.4          See http://www.oaic.gov.au/privacy/making-a-privacy-complaint for further information.

  1. General

This Policy reflects Haircare Australia's Credit Information Management Policy as at 28/09/2014 and replaces all previous Credit Information Management Policies.  Haircare Australia will review this Policy from time to time, and incorporate amendments in the updated Policy.  The amended Policy will be published on this website.

  1. Privacy Officer

Haircare Australia's Privacy Officer can be contacted as follows:

Privacy Officer
Haircare Australia
Corner Adam & Manton St
Hindmarsh
SA 5007

Phone: +61 8 8403 8282

Fax: +61 8 8403 8210

Email: privacy@haircareaust.com