Greater Bank Ltd
Australian Privacy Principle and Credit Information Policy
Greater Bank Ltd (ABN 88 087 651 956) ('we', 'us', 'our') is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act). We are also bound by Division 3 of Part IIIA of the Privacy Act, which regulates the handling of credit information, credit eligibility information and related information by credit providers and the Credit Reporting Privacy Code.
This Australian Privacy Principle and Credit Information Policy (Policy) outlines how we deal with your personal information (including credit-related information), as well as our legal obligations and rights as to that information. If we agree with you to use or disclose any of your personal information in ways which differ to those stated in this Policy, the provisions of that agreement will prevail to the extent of any inconsistency.
1. Key types of information
Certain words have special meanings when used in this APP Privacy and Credit Information Policy. These are shown below.
"Personal information" means information or an opinion about an individual who is identified, or who can reasonably be identified, from the information. Although we try to make sure that all information we hold is accurate, "personal information" also includes any inaccurate information about the individual.
"Credit eligibility information" means information that has been obtained from a credit reporting body, or that has been derived from that information, that is about an individual's credit worthiness.
"Credit information" means personal information that includes the following:
- information about an individual, like their name and address, that we may use to identify that individual
- information about an individual's current or terminated consumer credit accounts and, from 12 March 2014, an individual's repayment history
- the type and amount of credit applied for in any previous consumer or commercial credit applications to any credit provider, where that credit provider has requested information
- information about an individual from a credit reporting body
- information about consumer credit payments overdue for at least 60 days and for which collection action has started
- advice that payments that were previously notified to a credit reporting body as overdue are no longer overdue
- information about new credit arrangements an individual may have made with a credit provider, in relation to consumer credit currently or previously held, to deal with any defaults or serious credit infringements by that individual
- information about court judgments which relate to credit that an individual has obtained or applied for
- information about an individual on the National Personal Insolvency Index
- publicly available information about an individual's credit worthiness, and
- an opinion of a credit provider that an individual has committed a serious credit infringement of credit provided by that credit provider.
We may not hold all of these kinds of information about a particular individual. However, if we hold any of these kinds of information, it is protected as "credit information" under this Policy.
"Credit-related information" means credit information, credit eligibility information and related information.
Wherever possible, we will collect personal information (including credit information) directly from you. This information will generally come from what you provide in your application for one of our products or services and supporting documentation.
We only ask for personal information relevant to our business relationship with a customer. When you apply for one of our products or services, we may request:
- identifying information, like your name, address and other contact details and your date of birth
- information about your financial position, like your income, expenses, savings and assets and any (other) credit arrangements
- your employment details
- your tax file number, and
- your reasons for applying for a product or service.
We may also collect personal information (including credit-related information) about you from third parties, such as any referees that you provide, your employer, other credit providers and third party service providers including credit reporting bodies.
Credit reporting bodies collect credit information about individuals which they provide as credit reports to credit providers and others in the credit industry to assist them in managing credit risk, collecting debts and other activities.
You can also ask a credit reporting body, through contact details on their website, not to use or disclose your personal information if you believe on reasonable grounds that you have been or are likely to be a victim of fraud, including identity fraud.
Some information is created through our internal processes, like credit eligibility scoring information.
We may use your personal information (including credit-related information) for the purpose of providing products and services to you and managing our business. This may include:
- assessing and processing your application for the products and services we offer
- establishing and providing our systems and processes to provide our products and services to you
- executing your instructions
- charging and billing
- uses required or authorised by law
- maintaining and developing our business systems and infrastructure
- research and development
- collecting overdue payments due under our credit products
- managing our rights and obligations regarding external payment systems, or
- direct marketing.
In general, we do not use or disclose your personal information (including credit-related information) for a purpose other than:
- a purpose set out in this Policy
- a purpose you would reasonably expect
- a purpose required or permitted by law, or
- a purpose otherwise disclosed to you to which you have consented.
We may disclose your personal information (including credit-related information) to other organisations, for example:
- our related companies
- external organisations that are our assignees, agents or contractors
- external service providers to us, such as organisations which we use to verify your identity, payment systems operators, mailing houses and research consultants
- insurers and re-insurers, where insurance is provided in connection with our services to you
- superannuation funds, where superannuation services are provided to you
- other financial institutions, for example, when you apply for a loan from another credit provider and you agree to us providing information
- credit reporting bodies, including disclosing that you are in default under a credit agreement or commit a serious credit infringement, if that is the case
- lenders' mortgage insurers, where relevant to credit we have provided
- debt collecting agencies, if you have not repaid a loan as required
- our professional advisors, such as accountants, lawyers and auditors
- state or territory authorities that give assistance to facilitate the provision of home loans to individuals
- certain entities that have bought or otherwise obtained an interest in your credit product, or that are considering doing so, and their professional advisors
- your representative, for example, lawyer, mortgage broker, financial advisor or attorney, as authorised by you, or
- if required or authorised by law, to government and regulatory authorities.
We will take reasonable steps to ensure that these organisations are bound by sufficient confidentiality and privacy obligations with respect to the protection of your personal information.
We may disclose your personal information overseas, including your credit information and credit eligibility information. The countries where we are likely to disclose your personal information, including your credit information or credit eligibility information, include New Zealand, United States of America and/or Germany.
However, if we do disclose this information outside Australia, we will do so on the basis that the information will be used only for the purposes set out in this Policy.
5. Sensitive information
Where it is necessary to do so, we may collect personal information about you that is sensitive. Sensitive information includes information about an individual's health, and membership of a professional or trade association.
Unless we are required or permitted by law to collect that information, we will obtain your consent. However, if the information relates directly to your ability to meet financial obligations that you owe to us, you are treated as having consented to its collection.
6. Refusal of credit applications
We may refuse an application for consumer credit made by you individually or with other applicants. Our refusal may be based on credit eligibility information obtained from a credit reporting body about either you, another applicant or another person proposed as guarantor.
In that case, we will give you written notice that the application has been refused on the basis of that information. We will tell you the name and contact details of the relevant credit reporting body and other relevant information.
We take all reasonable steps to ensure that your personal information (including credit-related information), held on our website or otherwise, is protected from:
- misuse, interference and loss, and
- unauthorised access, disclosure or modification.
We ask you to keep your passwords and personal identification numbers safe, in accordance with our suggestions.
When we no longer require your personal information (including when we are no longer required by law to keep records relating to you), we take reasonable steps to ensure that it is destroyed or de-identified.
This section explains how we handle personal information and credit information collected from our website. If you have any questions or concerns about transmitting your personal information via the internet, you may contact our Customer Service Manager, whose details are in paragraph 14 of this Policy, as there are other ways for you to provide us with your personal information.
Visiting our website
Anytime you access an unsecured part of our website, that is, a public page that does not require you to log on, we will collect information about your visit, such as:
- the time and date of the visit
- any information or documentation that you download
- your browser type, and
- internet protocol details of the device used to access the site.
Our website also includes a number of calculators, which may require you to enter your personal details. If you save the data you enter on the calculator, this information will be stored.
You may change the settings on your browser to reject cookies, however doing so might prevent you from accessing the secured pages of our website.
In addition, we may transmit web site usage information about our site visitors to third party ad servers for the purpose of targeting our Internet banner advertisements on other sites. To do this, we use Web beacons and cookies provided by our third party ad servers on our site. The information that is collected and logged on our behalf through this technology is not personally identifiable to our third party ad servers and we do not capture or transmit any web site usage information that can personally identify you.
We currently use Google cookies to service adverts to its visitors across the Google Content Network. For more information about this and to opt out of this advertising, please click here:
Additionally, we have enabled Google Analytics to collect data about our advertising traffic via Google advertising cookies and anonymous identifiers, and have enabled the following Google Analytics Advertising Features: Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting and integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers.
You can opt-out of your data being used by Google Analytics here: https://tools.google.com/dlpage/gaoptout/
We also use the ClickTale customer experience analytics service on this site. The ClickTale service helps us analyse how visitors use our website. We do not collect through the ClickTale service or transfer to ClickTale any information that can personally identify you.
We only use the ClickTale service to record, on a completely anonymous basis, information such as mouse clicks, mouse movements, scrolling activity as well as non-personally identifiable information text you type into the website.
We may also collect information by way of real time surveys while you are navigating our website for the purpose of receiving feedback on your experiences in using our website. The survey questions are not compulsory but if you choose to provide us with your feedback none of the information we collect can personally identify you.
When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so.
Your email address will only be used or disclosed for the purpose for which is was provided. It will not be added to any mailing lists or used for any other purpose without your consent.
We use up-to-date security measures on our website to protect your personal information and your credit information. Any data containing personal, credit or related information which we transmit via the internet is encrypted. However, we cannot guarantee that any information transmitted via the internet by us, or yourself, is entirely secure. You use our website at your own risk.
Links on our website
You may request access to the personal information (including credit-related information) that we hold about you at any time from your local branch or by calling our Service Centre on 1300 651 400 during business hours.
We will respond to your request for access within a reasonable time. If we refuse to give you access to any of your personal information, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. You can contact our Customer Service Manager if you would like to challenge our decision to refuse access.
We may recover the reasonable costs of our response to a request for access to personal information.
We take reasonable steps to make sure that the personal information (including credit-related information) that we collect, use or disclose is accurate, complete and up-to-date. However, if you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting your local branch or by calling our Service Centre on 1300 651 400 during business hours.
We may use your personal information, including your contact details, to provide you with information about products and services, including those of third parties, which we consider may be of interest to you. We are permitted to do this while you are our customer, and even if you are on the Do Not Call Register.
We may also provide your details to other organisations for specific marketing purposes.
We will consider that you consent to this, unless you opt out. You may opt out at any time if you no longer wish to receive marketing information or do not wish to receive marketing information through a particular channel, like email. In order to do so, you will need to request that we no longer send marketing materials to you or disclose your information to other organisations for marketing purposes. You can make this request by contacting, your local branch or by calling our Service Centre on 1300 651 400 during business hours or by 'unsubscribing' from our email marketing messages, which always include an unsubscribe option.
To help us reach the right people with our credit direct marketing, we may ask a credit reporting body to "pre-screen" a list of potential recipients of our direct marketing against our eligibility criteria to remove recipients that do not meet those criteria. From 12 March 2014, the credit reporting body cannot use information about your existing loans or repayment history in carrying out its pre-screening and it must destroy its pre-screening assessment once it has given us, or a contractor acting on our behalf, the list of eligible recipients. If you do not want your credit information used for pre-screening by a credit reporting body that holds credit information about you, you can opt-out by informing that credit reporting body, whose contact details are on their website above.
12. Changes to the Policy
We may make changes to this Policy from time to time (without notice to you) that are necessary for our business requirements or the law. Our current Policy is available on our website www.greater.com.au
13. Questions and complaints
If you have any questions, concerns or complaints about this Policy, or our handling of your personal information (including credit-related information), please contact your local branch or by calling our Service Centre on 1300 651 400 during business hours You can also contact the Customer Service Manager if you believe that the privacy of your personal information has been compromised or is not adequately protected.
Once a complaint has been lodged, the Customer Service Manager will respond to you as soon as possible. We will aim to deal with your complaint at the source of your complaint. If you are not satisfied with the response you receive, please let us know and our Disputes Committee will investigate further and respond to you.
If you are still not satisfied, you can contact external bodies that deal with privacy complaints. The Credit & Investments Ombudsman Limited which is our external dispute resolution scheme, or the Federal Privacy Commissioner. Any of these bodies may forward your complaint to another external dispute resolution body if it considers the complaint would be better handled by that other body.
Credit & Investments Ombudsman
Post: PO Box A252, Sydney South NSW 1235
Telephone: 1800 138 422
Federal Privacy Commissioner
Post: GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
14. Customer Service Manager
Our Customer Service Manager's contact details are:
Address: P O Box 173, Hamilton NSW 2303
Telephone: 1300 651 400