How we handle your information
Keystart is committed to protecting the privacy and security of your personal information including your credit information.
In this policy, 'We', 'Keystart Group', 'us' and 'our' refer to Keystart Loans Ltd ACN 009 427 034 in its own right and as trustee for the Keystart Housing Scheme Trust (Keystart) and Keystart Scheme Management Pty Ltd ACN 120 164 847.
This policy explains how we protect, collect, store, use and disclose your personal information (including credit information). We are bound by the Privacy Act 1988 (Cth) (Privacy Act), including Part IIIA of the Privacy Act and the Australian Privacy Principles contained in the Privacy Act, as well as the Privacy (Credit Reporting) Code 2014 (CR Code).
We collect personal information including credit information.
Personal information means 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.
Personal information we collect may include:
The personal information we collect about you may also include credit information (which is described further below).
The personal information that we collect about you will depend on the loan type that you apply for or enquire about. Keystart will only collect personal information that is relevant to your loan application or that is necessary for the ongoing management and administration of your loan.
Sensitive information is a subcategory of personal information. It includes health information and information about your ethnicity. Under the Privacy Act, sensitive information can only be collected when we have your express consent or in certain other permitted situations. We generally only collect sensitive information if:
Credit information is personal information that, in broad terms, relates to the credit that has been provided to you or that you have applied for. It includes information supplied to us by a credit reporting body, and any information that we derive from it.
When you apply for a loan, we will obtain a credit report which contains information about your credit history. A credit report contains information which assists us to assess your application, including information about your credit history with other credit providers. Credit reports are designed to assist credit providers to accurately assess an individual's ability to repay credit.
We also collect other credit information about your financial position including:
We usually collect personal information directly from you or from a person that you have authorised to give your information to us. We collect this information when you interact with us – for example where you:
When you interact with us on our website, we collect some personal information using cookies (for more information please see the website terms and conditions.
We may also need to collect personal information (including credit information) about you from third parties, such as:
The main reason we collect, hold and use personal information (including credit information) is to provide you with products and services, and to assist us in managing our business. As part of this, we collect, hold and use your personal information in order to:
The Privacy Act and the CR Code limit what we can do with the information we obtain from a credit reporting body. It can usually only be used in relation to consumer credit products you have with us.
We may use your personal information to let you know about new or existing products or services that we think might be of interest or value to you. We may provide your personal information to third parties that provide direct marketing services for Keystart.
To do this, we may contact you by email, phone, SMS, social media, mail, Keystart and third-party apps or Keystart or third-party websites.
We will not send you direct marketing messages if you inform us that you do not want to receive them. You can opt-out or change your marketing preferences by:
We will not use any information that we have received from a credit reporting body 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. See the 'Sharing credit information' section for information about how you can contact the credit reporting body if you do not want them to use your information in this way.
If you do not provide us with the personal information that we reasonably request, Keystart may be unable to provide you with a loan or to provide other services to you.
Keystart may share your personal information (including credit information) with the entities in the Keystart Group.
We may also share this information with people and organisations outside of the Keystart Group where that third party assists in relation to the establishment or administration of your loan or supports the provision of services to you. We only provide these third parties with the information needed to provide the service or comply with the law.
The types of third parties that we may share your personal information (including credit information) with include:
We may also share your personal information (including credit information) with third parties where:
Some of the parties with which we share your personal information (including credit information), such as our contracted service providers, are located or operate outside of Australia. The countries where we are likely to disclose personal information are Germany, America and Japan. Where we send information overseas, we ensure there are arrangements in place to protect your information.
Keystart participates in the credit reporting system. We exchange certain information with credit reporting bodies.
If we are requesting a credit report about you from a credit reporting body, we may provide the credit reporting body with:
If you receive a loan from us, we will provide certain information to the credit reporting body as part of CCR including:
You should be aware that:
The credit reporting body we exchange information with is Equifax.
Equifax can be contacted by post, phone, email or online using the contact details set out below:
Equifax Australia Information Services and Solutions Pty Limited
PO Box 964
North Sydney NSW 2059
Telephone: 13 83 32
We take reasonable steps to make sure that the personal information (including credit information) that we collect, use or disclose is accurate, complete and up to date.
You can request access to and ask that we correct the personal information (including credit information) we hold about you. There is no fee for requesting a correction to your personal information or for us to make corrections. There may be a reasonable charge for giving you access to your personal information to cover our costs for locating and giving this information to you (but there is no fee for simply making the request).
Requests for access and correction to your personal information can be made by post or email at the following details:
Attention: Privacy Officer
PO Box 2016
Subiaco WA 6904
If you have requested access to your personal information, the Privacy Officer will then contact you to advise you of the timeframe for collecting or viewing your personal information and any associated fee (which must be paid before the information is provided to you). Once your information is available, you will need to come to our offices and provide satisfactory evidence of your identity to collect or view your information (or we may agree with you an alternative way for you to access your information).
There are certain circumstances where the law permits us to not provide you access to certain personal information that we hold about you. For example, we do not need to provide you access to your personal information where:
If we refuse to give you access to or to correct your personal information, we will give you notice:
If we refuse your request to correct your personal information, you can request that a statement be linked with your personal information noting that you do not agree with the accuracy of the information.
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.
Your personal information (including credit information) is kept in both hard copy and electronic form. We may use cloud storage to store the personal information we hold about you.
The electronic information is stored in secure monitored storage areas located in Australia and Germany (including storage areas owned and operated by our contracted service providers).
We use a range of security measures to protect the security and confidentiality of your personal information. These measures include the following:
When we no longer require your personal information (and are no longer required by law to keep it) we take reasonable steps to destroy or permanently de-identify it.
Although we take reasonable measures to protect your personal information, no data transmission over the internet can be guaranteed to be fully secure. Please contact us immediately if you think that your interaction with us is no longer secure.
If you have a query or complaint regarding how your personal information is being handled by us
(including about a breach of the Australian Privacy Principles or an applicable code), you can contact
The Complaints Manager
PO Box 2016
Subiaco WA 6904
If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. We will let you know we have received your complaint within seven days of receipt of your complaint. If we cannot resolve your complaint within 30 days, we will get in touch to tell you why and agree a new timeframe with you.
If you are not satisfied with how we have managed your complaint or our decision after you have 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. Before AFCA can investigate your complaint, they generally require you to have first provided us with the opportunity to address the complaint (see the section titled ‘Making a privacy complaint’ for details of how you can lodge your complaint with Keystart).
You can contact AFCA between 9am and 5pm (Sydney time) Monday to Friday using the contact details set out below.
AFCA 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 (OAIC) using the contact details set out below. The OAIC requires you to first make your complaint to us. We have 30 days to deal with your complaint before you are able to make a complaint to the OAIC.