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:

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”):

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:

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:

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:

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:

You should be aware that:

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.

Direct Marketing

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:

  1. You must send a signed, written request to the Privacy Officer to view your information.
  2. 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.
  3. 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:

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.

Website Security

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.

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website.

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:

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:

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
Website: www.cio.org.au
Email: .(JavaScript must be enabled to view this email address)

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:

The Privacy Officer
Keystart Home Loans
PO Box 6679
East Perth WA 6892