Keystart’s Privacy and Credit Reporting Policy (“Policy”)
How we handle your information
1. About Keystart
In this policy, ‘We’, ‘us’ and ‘our’ refer to Keystart Loans Ltd (Keystart) ACN 009 427 034, Australian Credit Licence 381437 its related companies and those agencies for whom we act as agents being the Housing Authority
and Country Housing Authority.
2. Our commitment to protect your privacy
We understand how important it is to protect your privacy. We have systems and procedures in place to protect your privacy and confidentiality whenever we collect, store, use or disclose your personal information, credit information and credit eligibility
This policy explains how we protect your Information and aim to be clear and open about what we do with it.
We recognise that any information we collect about you will only be used for the purposes
we have collected it for or as allowed under the law.
Keystart abides by the Australian Privacy Principles (APPs) and Part IIIA of the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2014.
Sometimes we update
3. What information do we collect?
We collect Personal Information and Credit Related Information (together known as, Information).
What is personal
When we refer to personal information we mean information or an opinion (including information or an opinion forming part of a database), whether true or not, whether recorded in a material form or not, about an individual
whose identity is apparent, or can be reasonably ascertained, from the information or opinion.
The personal information we hold about you may also include Credit Related Information.
Personal Information we collect from you may
- Information about your identity —your name, address, contact details, date of birth, gender, marital status, dependants, occupation, driver's licence number
- Health Information
and transaction information
- Employment details
- Other personal information, such as details of your interactions with us.
Keystart will only ask for personal information that is relevant to your loan application or
that is necessary for the ongoing management and administration of your loan.
In addition to collecting information about your credit history from a credit reporting body, we also collect this type of information through your use
of Keystart products. For instance, we collect information about the credit you hold through Keystart and how you make repayments on those credit products. We collect this information to help manage the product you hold with Keystart. For example,
Keystart may use this information to determine whether you need assistance to meet your repayment obligations. Some of this information about the credit you hold with Keystart is disclosed to a credit reporting body so it can be included in your credit
report and shared with other credit providers that participate in the credit reporting system.
What is Credit Related Information?
Credit-related information includes both Credit information and Credit eligibility information.
Credit information is personal information (other than Sensitive Information) which relates primarily to your credit-related dealings with us. This information may be disclosed to credit reporting bodies in certain circumstances.
eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.
Credit Related Information we collect from you may include:
credit liability information about you (such as information relating to consumer credit accounts you have held with us);
- repayment history information about you (such as whether repayments have been made on time previously by you
and where a payment was overdue, when it was ultimately paid);
- a statement that an information request in relation to you has been made by us to a credit reporting body;
- the type of consumer credit, and the amount
of credit sought in an application that has been made by you to us and in connection with which we have made an information request in relation to you;
- default information about you (ie information regarding payments which have remained
overdue for over 60 days);
- payment information about you (ie information regarding the payment of moneys by you following a default);
- new arrangement information about you (ie information regarding arrangements
entered into as a result of you being overdue in making payments to us);
- court proceedings information about you (ie information about whether an Australian court has made a judgment against you that relates to credit applied for
- personal insolvency information about you (ie information recorded in the National Personal Insolvency Index about you);
- 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 personal insolvency information; or
- the opinion we have on reasonable grounds that you have committed
a serious credit infringement in relation to credit we have provided to you;
- your credit risk rating;
- your credit score; and
- your credit information relating to your dealings with other credit providers.
When we obtain credit information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.
Act places restrictions on collecting sensitive information (including religion, ethnicity, criminal history and sexual preference). Generally we will not collect sensitive information; however we may collect sensitive information if it is required
by law or you are applying for a specific loan product (for example Aboriginality when applying for an Aboriginal Home Ownership Scheme loan or disability information when applying for an ACCESS Home Loan).
4. How do we collect Information?
We collect information directly from you when you interact with us to:
- apply for, register your interest in, or enquire about a product or service;
- provide us with feedback or make a complaint;
to us, or do business with us; and
- visit our interactive website. We collect some of this information using cookies (for more information please see the Website Terms and Conditions here.
From time to time we collect personal information
about you from third parties, such as:
- Any credit provider named in your loan application,
- Credit reporting bodies and credit providers named in any credit reports about you,
- Any person or body who may provide reports
on your commercial activities and your commercial credit worthiness,
- Any person or body in relation to information you have disclosed in your application,
- Any local government office or other government authority,
- Any other person that Keystart may require information from in relation to the assessment and monitoring of your loan provided Keystart provides you with prior notice of our intention to collect that information, and
- Your transactions
in connection with the credit provided by us, such as when you make payments to us.
About Credit Reporting
Keystart participates in the credit reporting system. If you apply for credit from Keystart, we may request a credit report about
you from a credit reporting body. A credit report contains information which assists us to assess your application, including information about your credit history with other credit providers. Credit reporting bodies can provide credit providers with
credit reports in certain circumstances, including when an individual makes an application for credit, or when a credit provider is seeking to help an individual avoid defaulting on their credit. Credit reports are designed to assist credit providers
to accurately assess an individual’s ability to repay credit.
Occasionally, Keystart may collect your credit information directly from other credit providers, including other banks. Keystart will collect information from other credit providers
with your consent.
5. Why we collect Information
Keystart collects and uses your Information for several purposes including to:
- assist us in making responsible lending decisions.
- assess your credit worthiness,
- assess and evaluate loan applications,
- fulfil our obligations under the National Consumer Credit Protection Act 2009 (Cth) and otherwise comply with relevant laws, regulations, codes of practice and external payment systems,
- maintain and monitor loans that have been approved over the term of the loan,
- provide statistical data to members of the Keystart Group,
- exchange information with other credit providers about you to the extent
that is permitted under the Privacy Act,
- monitor and evaluate our products and services,
- gather and aggregate information for statistical, prudential, actuarial and research purposes and for our internal operations including
record keeping, risk management, auditing purposes, transactions, credit scores and file reviews,
- take measures to detect and prevent frauds and credit loss,
- predict the borrowing behaviour of customers generally,
- to help manage the product you hold with Keystart. For example, Keystart may use this information to determine whether you need assistance to meet your repayment obligations. Some of this information about the credit you hold with Keystart
is disclosed to a credit reporting body so it can be included in your credit report and shared with other credit providers that participate in the credit reporting system. and
- monitor, resolve and prevent complaints you may raise against
Keystart and/or to manage legal action between you and Keystart.
From time to time, we may also use your information to tell you about products or services we think you might be interested in.
- As part of
Keystart’s service to you, Keystart only uses your personal information for direct marketing that relates to new or existing products and services provided by the Keystart Group or to manage the entitlements of introducers. This may involve
giving the information to third parties that are contracted by Keystart to provide that service for Keystart including The Brand Agency.
- Keystart may contact you in relation to marketing our products. However, we will not do so if
you tell us not to.
- Keystart will not use any information that we have received through the credit reporting system for marketing purposes. However, for some products, Keystart may ask a credit reporting body to use the credit reporting
information they hold to identify individuals that are eligible for a Keystart marketing offer. If you are eligible, you may be sent an offer on Keystart’s behalf. You should contact the credit reporting body directly if you do not want them
to use your information in this way.
- If at any time you wish to opt-out of receiving marketing information, you may do so by calling 1300 578 278 or in the case of email, you may use the ‘unsubscribe’ facility included in the
- Additionally, as a Keystart customer, you can log into Keystart’s client portal and change your marketing preferences at any time via the contact details option.
What if you choose not to provide the Information
Keystart only collects information that is necessary for the purposes listed above. If you choose not to provide the information requested, Keystart may be unable to provide you with a loan. However, where it is lawful and practical
to do so, we will offer you the opportunity of doing business with us without providing us with personal or credit information, for example, if you make general enquiries about interest rates or loan criteria with Keystart.
6. Who do we share
your information with?
Keystart may, where permitted by the Privacy Act, disclose your Information:
- Within the Keystart Group and to contractors or introducers that must be contacted to assess and (if approved) grant your
loan and, after that, to manage the entitlements of any introducers involved in your loan application and to generally manage the loan,
- To our related entities and service providers such as when we outsource certain functions, including
bulk mailing, market research, direct marketing and debt recovery,
- To our legal advisers,
- To insurers and re-insurers,
- To any Auditor we appoint to ensure the integrity of our operations,
- To any valuers of security property,
- To any person engaged by Keystart in relation to your loan application,
- Any persons involved in funding mortgages credit,
- To the credit reporting body Veda Advantage of Level
15, 100 Arthur Street, North Sydney, NSW (“Veda”) or any other credit reporting body specified in this policy from time to time. A copy of Veda’s credit reporting policy can be obtained by contacting Veda by email at email@example.com
or via their website at www.veda.com.au/credit-reporting-policy,
- To external complaint resolution bodies, where required in connection with a complaint,
- To any person who represents you, such as finance brokers, settlement
agent, builder and real estate agents, or
- To any other person permitted under the Privacy Act.
- To request a credit report, Keystart will provide information to the credit reporting body that identifies you, as well as information
about your application – including the type and amount of credit you are applying for.
Prior to disclosing any of your Information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
- The person or organisation has a commitment to protecting your personal information and credit-related personal information at least equal to our commitment, or
- You have consented to us making the disclosure.
You should be aware that:
- credit reporting bodies may include credit information we provide to them about you in reports provided to other credit providers to assist them to assess your credit worthiness,
- if you fail to meet your payment obligations
in relation to consumer credit, or commit a serious credit infringement, we may disclose this to a credit reporting body,
- you can request a credit reporting body not to use your credit reporting information for the purposes of pre-screening
or direct marketing by us, and
- you can request a credit reporting body not to use or disclose your credit reporting information if you believe on reasonable grounds that you have been (or are likely to be) a victim of fraud.
Sending information overseas
Keystart will not send your personal information outside Australia unless we are satisfied that the overseas recipient of the information has adequate data protection arrangements in place, or you have consented
to the transfer of the information.
Keystart may disclose your personal information to our third party services providers for them to help us provide lending services to you. Our third party service providers may store or access your personal
7. Accessing and seeking correction of your Information
We aim to make sure that the personal and credit-related information we collect, use or disclose is accurate, complete and up to date. We take reasonable
steps to make sure that this is the case.
Subject to some exemptions, you can access and correct most of your personal and credit-related personal information held by Keystart using the following procedure:
- You must send a signed,
written request to the Privacy Officer to view your information.
- Within 14 days of receiving the letter the Privacy Officer will contact you to advise the timeframe for collecting your information, the ways in which the information can
be accessed, and the cost for providing the information. If you would like to proceed with the provision of your information you must notify the Privacy Officer and pay any required fee. The fee is for the time we spend locating, collating and explaining
the information you request plus any photocopying costs and out of pocket expenses.
- Upon the information being available you must come to our offices and provide satisfactory evidence of your identity to collect or view the information.
You may be unable to access some of the personal and credit-related personal information that Keystart has about you. Keystart is permitted under the Privacy Act to deny access if particular circumstances apply. If this is the case, the Privacy
Officer will inform you of this and provide you with the reason for the denial of access. Some examples of denied access are:
- Access will pose a threat to the life or health of anyone,
- Access would have an unreasonable impact,
- The information relates to anticipated or actual legal proceedings,
- Access is unlawful,
- Access would reveal the process of making sensitive commercial decisions.
If you believe that any personal or credit-related information
that Keystart holds about you is not accurate, complete or up to date, you should notify the Privacy Officer in writing as soon as possible.
If we do not agree that your information is inaccurate, incomplete or out of date, we will write
to you and tell you the reason(s) why we do not agree with you. We will also tell you what you can do if you are not satisfied with our response.
8. Your Information is secure
Your personal and credit-related personal information is kept
in both hard copy and electronic form. We may use cloud storage to store the personal information we hold on you.
When Keystart no longer requires your personal and credit-related personal information it is archived in secure storage facilities
both on and off site for at least 7 years and then destroyed.
The electronic information is kept in Keystart’s computer system. This system is held in a secure monitored storage area. Computer access can only be gained through a combination
of user ID and password. Passwords are automatically changed at frequent intervals to prevent unauthorised access.
To enable systems software maintenance, software support requires access to these systems. Any access is only permitted after proper
9. Making a privacy complaint
If you have any queries regarding this Policy, a complaint regarding the failure of Keystart to comply with the Privacy Act or an applicable code or would like to discuss any concerns, then you
may contact Keystart in a number of ways:
- You can speak to our staff directly who will do their best to resolve any concerns that you may have, on 1300 578 278.
- You can email the Privacy Officer at firstname.lastname@example.org
Credit information complaints
If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. We’ll let you know we’ve received your complaint within
seven days. If we can’t sort it out within 30 days, we’ll get in touch to tell you why and work out a new timeframe with you.
What else can you do?
If you're not satisfied with how we manage your complaint or our
decision after you've been through our internal complaints process, the Australian Financial Complaints Authority (AFCA) offers a free independent dispute resolution service for consumer and small business complaints. You can contact AFCA between
9am and 5pm (Sydney time) Monday to Friday.
The Australian Financial Complaints Authority can consider most complaints involving financial services providers.
If your complaint is about how we handle your personal
information, you can also contact the Office of the Australian Information Commissioner.
Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
1800 931 678 (free call)
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992