Privacy and Credit Reporting Policy (“Policy”)
Our Privacy Commitment to You
Keystart is committed to protecting the privacy and confidentiality of our customers’ personal information, credit information and credit eligibility information.
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 information.
Keystart complies with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles set out in the Privacy Act with respect to the collection, storage, use and disclosure of personal information, credit information and credit eligibility information.
About this Policy
This Policy explains the kinds of personal information, credit information and credit eligibility information that Keystart collects and holds about you, the purposes for which that information is collected and held and how Keystart collects, holds, uses and discloses that information.
Keystart may make changes to this Policy from time to time. We encourage you to check our website regularly for any updates to this Policy.
References to Keystart or the Keystart Group in this policy means Keystart Loans Limited, Keystart Country, its related companies and those agencies for whom we act as agents being the Housing Authority and Country Housing Authority.
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.
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.
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.
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.
What is Personal Information, Credit Information and Credit Eligibility Information?
Personal information is 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.
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.
Credit eligibility information refers to information disclosed to us by credit reporting bodies and the information that we derive from your credit reporting information as to your credit worthiness (for example, a credit score).
The terms credit information and credit eligibility information are collectively referred to as credit-related personal information in this Policy.
Why We Collect Personal Information
Keystart collects and uses your personal and credit-related personal information for several purposes including to assess, provide and maintain a housing loan to you.
Keystart collects and uses your personal information and credit-related personal information to:
- assess your credit worthiness,
- assess and evaluate loan applications,
- facilitate third party acquisition, by assignment, transfer or otherwise, of Keystarts’ rights or interests under any Keystart mortgage, or any contract relating to that mortgage, with you,
- 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, and
- monitor, resolve and prevent complaints you may raise against Keystart and/or to manage legal action between you and Keystart
What Sort of Information do we Collect?
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. This includes information such as your name, address, contact details, date of birth, gender, marital status, dependants, occupation, driver’s licence number, employment details, banking details and other financial information. We may also collect details of any complaints you may have against us and to manage a complaint from you.
We use your personal information to assist us in making responsible lending decisions.
The Privacy 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).
What Sort of Credit Information do we Collect?
Keystart may collect all types of credit information that is relevant to our credit products. This includes the following types of information collected by us that we may give to a credit reporting body such as Veda Advantage Limited (“Veda”):
- identification information about you (such as your name, address, date of birth and occupation);
- consumer 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 by you);
- 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.
The credit information collected about you may be held by us in electronic form on our secure servers and may also be held in paper form. We may also use cloud storage to store the credit information we hold about you.
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.
What Kind of Credit Eligibility Information do we Hold?
We may hold credit eligibility information about you relevant to our credit products including, without limitation:
- your credit risk rating;
- your credit score; and
- your credit information relating to your dealings with other credit providers.
How do we Collect Personal Information and Credit Information?
Keystart will obtain personal information and credit information from you as part of your loan application including information provided through Keystart’s interactive website and online applications. Keystart obtains reports from credit reporting bodies about your credit history and Keystart may use those reports to check against the information you have provided in your loan application. Keystart may also obtain information about you from any other prior loan application with Keystart.
Keystart may also collect personal information and credit information about you from the following sources:
- 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.
What if you Choose not to Provide the Information we Request?
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.
Disclosure of Personal Information and Credit-Related Personal Information to Third Parties
Keystart may, where permitted by the Privacy Act, disclose your personal and/or credit-related personal information:
- To a BPAY Member Financial Institution that has contracted with Keystart for the provision of a BPAY payment system, and any agent appointed by the BPAY Member Financial Institution from time-to-time, including Cardlink Services Ltd;
- To the recipient of a BPAY payment made on your behalf (Biller);
- To the Biller’s financial institution; or
- To BPAY Pty Ltd.
- 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 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 any third party involved in the acquisition, by assignment, transfer or otherwise, of rights or interests under any Keystart mortgage, including, without limitation, potential investors, advisors, trustees and rating agencies,
- 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.
Prior to disclosing any of your personal and credit-related personal 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.
Cross-Border Disclosure of Information
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 information overseas.
What Kinds of Information do we Derive from Credit Reporting Information?
We utilize credit reporting information obtained from credit reporting bodies to derive information that assists us in assessing your creditworthiness, such as create a credit risk rating or credit score for you.
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 email.
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.
Accessing and seeking correction of your Personal Information and Credit-Related Personal Information
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.
We keep your Personal Information Accurate and up to date
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.
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 you ask Keystart to correct information that we have received through the credit reporting system or information that we have previously disclosed to credit reporting bodies, we will consult with other credit reporting bodies and credit providers about the accuracy of your information, as necessary. 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.
Your Personal 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 authorisation.
Keystart takes all reasonable precautions in keeping secure the information you provide us. We continually maintain and monitor our online security systems to ensure your personal information is appropriately protected.
You may be able to access external websites by clicking links we have provided. Whilst such links are provided for your convenience, you should be aware that the privacy standards and procedures might not be the same as ours.
You may access the Website Terms and Conditions at www.keystart.com.au/static/disclaimer.
Cookies, our website and emails
Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any information stored on your computer or your files.
When a server uses a web browser to read cookies they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.
Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in comment forms. You can browse our website anonymously without identifying yourself during your visit. We will only obtain information that personally identifies you when you specifically choose to provide it.
For example, during your visits to our web site you may:
- send messages or comments to us via the website, eg. through the "Contact Us" form; or
- conduct transactions online.
You will then need to give us certain personal information just as you would if you were communicating with us in person, by mail or by telephone.
If you choose to send us an e-mail message, we may retain the content of the e-mail, your e-mail address, and our response in order to service your needs.
Use of Government identifiers
Keystart does not use your tax file number, Medicare number or any other government identifier as your loan account or application number. We only use and disclose these numbers for the purposes required by law.
Resolving your Privacy concerns
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 send your query via mail to:
The Privacy Officer
Keystart Home Loans
PO Box 6679
East Perth WA 6892
In the unlikely event the Privacy Officer has not resolved your concerns you may seek assistance from Keystart’s External Dispute Resolution scheme, the Credit and Investments Ombudsman Ltd (CIO), or the Office of the Australian Information Commissioner.
Keystart’s CIO Membership number is: 400192
CIO's contact details are as follows:
Freecall: 1800 138 422 (mobile phone charges apply)
Phone: (02) 9273 8455
The Office of the Australian Information Commissioner can be contacted at www.oaic.gov.au or you can call them on 1300 363 992.
Is this Policy available in other formats (ie hard copy)?
You may seek other formats (such as a hard copy) of this Policy by contacting us as follows:
- You can speak to our staff directly on 1300 578 278.
- You can request the Policy via mail to:
The Privacy Officer
Keystart Home Loans
PO Box 6679
East Perth WA 6892