This Policy applies to ProMed Finance Australia Ltd ABN 42 109 517 688 (referred to as ‘ProMed’,‘we’,‘our’,‘us’). We recognise the importance of ensuring the confidentiality and security of your personal information.
All third parties (including customers, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by ProMed must abide by this Policy.
Copies of this Policy are available free of charge by contacting our Privacy Officer or can be downloaded from our website www.promedfinance.com.au.
This Policy outlines ProMed’s obligations to manage and protect your personal information. ProMed is bound by the Australian Privacy Principles (‘APPs’), the Credit Reporting Privacy Code (‘the Code’) and the Privacy Act 1988 (‘Privacy Act’). This Policy also outlines a number of ProMed’s practices, procedures and systems that ensure compliance with the Privacy Act, APPs and the Code.
In this Policy:
- ‘Credit information’ is personal information (other than sensitive information) that relates to an individual’s credit history or credit worthiness, and is further defined in the Privacy Act. Credit information includes information that we have obtained from third parties, including individuals, other credit providers and credit reporting bodies (‘CRBs’);
- ‘Disclosure’ of information means providing personal information to persons outside ProMed;
- ‘Individual’ means all persons whose personal information we collect, use or disclose;
- ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual. References in this policy to personal information include credit and sensitive information unless stated otherwise;
- ‘Sensitive information’ is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
- ‘Use’ of information means use of personal information within ProMed.
2. What kinds of personal information do we collect and hold?
We may collect and hold a range of information about you to provide you with our services, including your:
- full name;
- contact details;
- date of birth;
- employment details and history;
- education details;
- bank account details, balance and transaction history;
- identification information such as passport or drivers’ licence details;
- marital status and dependants;
- financial and credit information, including:
- details of assets, liabilities, income and expenses;
- information about your consumer credit liabilities, such as the name of an entity that has provided you with credit, the date the credit was provided and the maximum amount of credit made available;
- information about your repayment history, such as whether you were late in making a monthly repayment and when repayments were due;
- the type and amount of credit you sought in an application;
- whether you are deemed to be a credit risk according to the CRB we utilise; and
- whether you have repaid overdue payments.
3. How we collect personal information
We generally collect personal information directly from you. For example, personal information will be collected when you apply for credit or we otherwise interact with you in the course of providing you with our products and services, including when you visit our website, call us or send us correspondence.
ProMed will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exemptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If you do not provide us with the personal information we request, we may not be able to provide you with our products or services, or meet your needs appropriately.
ProMed does not give individuals the option of dealing with it anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for ProMed to deal with individuals who are not identified.
4. Unsolicited personal information
ProMed may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to ProMed’s purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
5. About whom do we collect personal information?
The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
- borrowers or potential borrowers;
- partners of borrowers or potential borrowers (only if relevant to the credit application);
- visitors to our website; and
- service providers or suppliers.
6. Why does ProMed collect and hold personal information?
We collect and hold personal information (excluding credit information) about you so that we may:
- provide you with our credit products and services;
- verify your identity and financial situation;
- assess whether our products or services are suitable for you;
- assess your application(s) for credit;
- manage credit provided to you, or collect overdue payments;
- review and meet your ongoing needs;
- provide you with information we believe may be relevant or of interest to you;
- let you know about other products or services we offer, send you information about special offers or invite you to events;
- consider any concerns or complaints you may have;
- comply with relevant laws, regulations and other legal obligations; and
- help us improve the products and services offered to our customers and enhance our overall business.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.
7. Who do we disclose personal information to?
We may disclose your personal information, excluding your credit information, to:
- a related entity of ProMed;
- an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, IT contractors, marketing companies, credit reporting body, debt collectors or other advisers;
- organisations involved in a transfer or sale of all or part of our assets or business;
- organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- your referee(s), employer, co-account holder, authorised signatory or relative or secondary contact as nominated by you during your loan application; and
- anyone else you authorise us to disclose it to.
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.
8. How do we use and disclose credit information?
We will only use your credit information to:
- assess your application(s) for credit;
- collect payments that are overdue in relation to credit we provided;
- deal with a serious credit infringement we believe you have committed;
- assist you to avoid defaulting on your obligations; or
- manage how we provide our credit products and services to you.
We will only disclose credit information to:
- a related body corporate;
- a person who will be processing your application for credit;
- a person who manages credit provided by us, for use in managing that credit;
- another credit provider if we believe you have committed a serious credit infringement, or you have consented to the disclosure;
- to a person considering whether to act as a guarantor or offer property as security and you have expressly consented to the disclosure;
- a debt collector;
- an external dispute resolution scheme of which we are a member;
- a CRB; or
- any other person or entity that is entitled or authorised by law to require us to disclose it.
If we intend to provide default information about you to a CRB, we will give you at least 14 days’ written notice. If we disclose default information to a CRB, and you subsequently repay the amount owed, we will tell the CRB you have repaid the amount owing.
9. Management of personal information
ProMed recognises the importance of securing the personal information of our clients. We will take steps to ensure your personal information is protected from misuse, interference, loss, unauthorised access, modification or disclosure.
Your personal information is generally stored in databases. Any paper files are stored in secure areas.
In relation to information that is held in the databases we use, we apply the following guidelines:
- data ownership is clearly defined within ProMed;
- passwords are routinely changed;
- we change employees’ access capabilities when they are assigned to a new position;
- the system automatically limits the amount of personal information appearing on any one screen;
- unauthorised employees are barred from updating and editing personal information;
- all personal computers which contain personal information are secured electronically;
- print reporting of data containing personal information is limited;
- access to the computer database is protected by 256 bit encryption with a 2048 bit signature;
- ProMed has created procedures for the disposal of personal information; and
- personal information is overwritten to the extent possible when the information is no longer required.
Sensitive information collected through the loan application is hosted in a secure, purpose built data centre which complies with the requirements of:
- certification ISO-27001 Information Systems and Security Management; and
- certification to ASIO T4 Intruder Resistance.
As part of the loan application and ongoing loan management processes, ProMed may from time to time collect or store personal information through:
- our website;
- the loan application process;
- electronic loan documentation;
- our app and the associated content management system (CMS);
- our customer relationship management (CRM) software; and
- customer surveys.
This personal information is not shared with any parties outside of ProMed other than as or when required for the purpose of providing you with our products and services in accordance with section 7.
All third party software providers used by ProMed to collect and hold data use a range of physical and electronic security measures to protect the security of the personal information they hold in data centres either in Australia or overseas.
10. Sending information overseas
We may disclose personal information to third party software providers we use for the purpose of collecting and holding data. These recipients may be located in the following countries:
- United Kingdom; and
- United States.
We will not send personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Act, the APPs and the Credit Reporting Privacy Code;
- the recipient is subject to an information privacy scheme similar to the Privacy Act; or
- the individual has consented to the disclosure.
If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
11. Direct marketing
ProMed may only use personal information we collect from you for the purposes of direct marketing without your consent if:
- the personal information does not include sensitive information; and
- you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
- we provide a simple way of opting out of direct marketing; and
- you have not asked to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications. We will not use your credit information for the purposes of direct marketing.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
• For Microsoft Internet Explorer: www.microsoft.com/info/cookies.mspx
• For Google Chrome: www.google.com/support/chrome/bin/answer.py?answer=95647
• For Mozilla Firefox: http://support.mozilla.com/en-US/kb/Enabling%20and%20disabling%20cookies
• For Apple Safari 5: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html
13. Online advertising we use
We use Google AdWords Remarketing to advertise ProMed across the Internet. AdWords Remarketing may display relevant ads tailored to you based on what parts of the ProMed website you have viewed by placing a cookie on your machine. This cookie does not in any way identify you or give access to your computer. The cookie is used to say “this person visited this page, so show them ads relating to that page”. Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
14. How to opt out of remarketing and advertising
If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager at www.google.com/settings/notsupported?hl=en&ref=/settings/u/0/ads/authenticated
We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.
16. How do we keep personal information accurate and up-to-date?
We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date.
We encourage you to contact us if any personal information we hold about you needs to be updated. If we correct information that has previously been disclosed to another entity, we will notify the other entity of the correction within a reasonable period. Where we are satisfied information is inaccurate, we will take
reasonable steps to correct the information within 30 days, unless you agree otherwise. We will not charge you for correcting your personal information.
17. Accessing your personal information
Subject to exceptions in the Privacy Act, you can access the personal information that we hold about you by contacting the Privacy Officer. We will generally provide access within 30 days of your request. If we refuse to provide you with access to the information, we will provide reasons for the refusal.
We will require identity verification and specification of what information is required.
18. Updates to this policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and the business environment.
It is the responsibility of management to inform employees and other relevant third parties about this Policy. Management must ensure that employees and other relevant third parties are advised of any changes to this Policy. All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.
20. Making a complaint
If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal information (including credit information) you may lodge a complaint with us by:
- telephoning 03 9863 3153; or
- writing to the ProMed Privacy Officer, Level 2/431 St Kilda Road, Melbourne VIC 3004; or
- emailing – email@example.com
If you are not satisfied with the result of your complaint to ProMed you can also refer your complaint to the Office of the Australian Information Commissioner.
You can contact the Office of the Australian Information Commissioner by:
- telephoning 1300 363 992; or
- writing to the Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001 or;
- emailing firstname.lastname@example.org