Respecting your privacy
covers Adelaide Residential Home Loans
This Policy also includes our credit reporting policy, that is, it covers additional
information on how we manage your personal information collected in connection with a
credit application, or a credit facility. We refer to this credit‐related information below as
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
• ID information such as your name, postal or email address, telephone numbers, and date of
• other contact details such as social media handles;
• financial details such as your tax file number; and
• other information we think is necessary.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to
collect it. There are laws which require us to collect personal information. For
example, we require personal information to verify your identity under Australian Anti‐Money
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of internet services to ensure we can
verify you and can receive information from us, and to identify ways we can improve our services
If you start but don’t submit an on‐line application, we can contact you using any
of the contact details you’ve supplied to offer help completing it. The information in
applications will be kept temporarily then destroyed if the application is not completed.
We also know that some customers like to engage with us through social media channels. We may
collect information about you when you interact with us through these channels.
However, for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de‐identified information
from web users. That information could include IP addresses or geographical information to ensure
your use of our web applications is secure.
How do we collect your personal information?
How we collect and hold your information
Unless it’s unreasonable or impracticable, we will try to collect personal information directly
from you (referred to as ‘solicited information’). For this reason, it’s important that you help
us to do this and keep your contact details up‐to‐date.
There are a number of ways in which we may seek information from you. We might
collect your information when you fill out a form with us, when you’ve given us a call or used our
also find using electronic means, such as email or SMS, a convenient way to communicate with you
and to verify your details1.
How we collect your information from other sources
Sometimes, we will collect information about you from other sources as the Privacy Act 1988
permits. We will do this only if it’s reasonably necessary to do so, for example, where:
• we collect information from third parties about the loan or lease made available to you
arising out of the services we provide you;
• we can’t get hold of you and we rely on public information (for example, from public
registers or social media) or made available by third parties) to update your contact details; or
• we exchange information with your legal or financial advisers or other representatives.
What if you don’t want to provide us with your personal information?
If you don’t provide your information to us, it may not be possible:
• for us to give you the credit assistance you seek from us;
• to assist in finding a loan or lease relevant to your circumstances;
• verify your identity or protect against fraud; or
• to let you know about other products or services that might be suitable for your financial
How we collect and hold your credit information
We will collect your credit information in the course of you answering the enquiries we make of you
relating to the credit assistance you seek from us. In addition to what we say above about
collecting information from other sources, other main sources for collecting credit information
• your co‐loan applicants or co‐borrowers;
• your guarantors/proposed guarantors;
• your employer, accountant, real estate agent or other referees;
• your agents and other representatives like the person who referred your business to
us, your solicitors, conveyancers and settlement agents;
• organisations that help us to process credit applications;
• organisations that check the security you are offering such as valuers;
• bodies that issue identification documents to help us check your identity; and
• our service providers involved in helping us to process any application you make
for credit through us.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out (referred to as
‘unsolicited information’). Where we receive unsolicited personal information about you, we will
check whether that information is reasonably necessary for our functions or activities.
If it is, we’ll handle this information the same way we do with other information we seek from
you. If not, we’ll ensure we do the right thing and destroy or de‐identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to
notify you how and why we collected your information, who we may disclose it to and
outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we
have done so. If we collect information that can be used to identify you, we will take reasonable
steps to notify you of that collection.
1 However we’ll never ask you for your security details in this way – if you are ever unsure, just
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of
your personal information is important to us and we take reasonable steps to protect
it from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Some of the ways we do this are:
• document storage security policies;
• security measures for access to our systems; and
• only giving access to personal information to a person who is verified to be able to receive
We may store personal information physically or electronically with third party
data storage providers. Where we do this, we use contractual arrangements to ensure
those providers take appropriate measures to protect that information and restrict the
uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We may be required
to keep some of your information for certain periods of time under law. When we no longer
require your information, we’ll ensure that your information is destroyed or de‐identified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Collecting your personal information allows us to provide you with the products and services you’ve
asked for. This means we can use your information to:
• give you credit assistance;
• give you information about loan products or related services including help, guidance and
• consider whether you are eligible for a loan or lease or any related service you requested
including identifying or verifying you or your authority to act on behalf of a customer;
• assist you to prepare an application for a lease or a loan;
• administer services we provide, for example, to answer requests or deal with complaints; and
• administer payments we receive, or any payments we make, relating to your loan or lease.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services
we or a third party make available and that may be of interest to you.
We will always let you know that you can opt out from receiving marketing offers.
With your consent, we may disclose your personal information to third parties for the
purpose of connecting you with other businesses or customers. You can ask us not to do this at
any time. We won’t sell your personal information to any organisation.
Yes, You Can Opt‐Out
You can let us know at any time if you no longer wish to receive direct marketing offers from us.
We will process your request as soon as practicable.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more
insight into the ways we use your personal information including:
• telling you about other products or services we make available and that may be of interest to
you, unless you tell us not to;
• identifying opportunities to improve our service to you and improving our service to you;
• allowing us to run our business efficiently and perform general administrative tasks;
• preventing any fraud or crime or any suspected fraud or crime;
• as required by law, regulation or codes binding us; and
• any purpose to which you have consented.
Who do we share your personal information with?
To make sure we can meet your specific needs and for the purposes described in ‘How we use your
personal information’, we sometimes need to share your personal information with others. We may
share your information with other organisations for any purposes for which we use your information.
Sharing Your Information
We may use and share your information with other organisations for any purpose described above.
Sharing with your representatives and referees We may share your information with:
• your representative or any person acting on your behalf (for example, lawyers, settlement
agents, accountants or real estate agents); and
• your referees, like your employer, to confirm details about you.
Sharing with third parties
We may share your information with third parties in relation to services we provide to you. Those
third parties may include:
• the mortgage aggregator through whom we may submit loan or lease applications to lenders or
lessors on the mortgage aggregator’s panel;
• the Australian Credit Licence holder that authorises us to engage in credit activities;
• referrers that referred your business to us;
• lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
• organisations, like fraud reporting agencies, that may identify, investigate and/or prevent
fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
• government or regulatory bodies (including ASIC and the Australian Taxation Office) as
required or authorised by law. In some instances, these bodies may share the information with
relevant foreign authorities;
• guarantors and prospective guarantors of your loan or lease;
• service providers, agents, contractors and advisers that assist us to conduct our business
for purposes including, without limitation, storing or analysing information;
• any organisation that wishes to take an interest in our business or assets; and
• any third party to which you consent to us sharing your information.
Sharing outside of Australia
We are not likely to disclose your information to organisations overseas. However, we may store
your information in cloud or other types of networked or electronic storage. As electronic or
networked storage can be accessed from various countries via an internet connection, it’s not
always practicable to know in which country your information may be held.
How do you access your personal information?
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons
why we can’t. You can ask us in writing to access your personal information that we hold. In some
cases we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s
reasonable and practical. We may charge you a small fee to cover our costs when giving you access,
but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations
where we don’t have to give you access include when:
• we believe there is a threat to life or public safety;
• there is an unreasonable impact on other individuals;
• the request is frivolous;
• the information wouldn’t be ordinarily accessible because of legal proceedings;
• it would prejudice negotiations with you;
• it would be unlawful;
• it would jeopardise taking action against serious misconduct by you;
• it would be likely to harm the activities of an enforcement body (e.g. the police); or
• it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing.
If you have concerns, you can complain. See ‘Contact Us’.
How do you correct your personal information?
How we correct your information
Contact us if you think there is something wrong with the information we hold about you and we’ll
try to correct it if it’s:
• irrelevant; or
If you are worried that we have given incorrect information to others, you can ask
us to tell them about the correction. We’ll try and help where we can ‐ if we can’t, then we’ll
let you know in writing.
What additional things do we have to do to correct your credit information?
If you ask us to correct credit information, we will help you with this in the following way.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you
ask for the information to be corrected. So we can do this, we might need to talk to others.
However, the most efficient way for you to make a correction request is to send it to the
organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding
to do this. We’ll also let the relevant third parties know as well as any others you tell us about.
If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days
of making this decision. If you have any concerns, you can access our external dispute resolution
scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you
asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
• let you know about the delay, the reasons for it and when we expect to resolve the matter;
• ask you to agree in writing to give us more time; and
• let you know you can complain to our external dispute resolution scheme or the Office of the
Australian Information Commissioner.
How do you make a complaint?
How do you generally make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you.
You are always welcome to contact us.
You can contact us by using the details below
• Who: Sarah Boccaccio
• Phone: 1300 447 026
• Email: email@example.com
• Mail: GPO Box 533, ADELAIDE SA 5001
We are committed to resolving your complaint and doing the right thing by our
customers. Most complaints are resolved quickly, and you should hear from us within five business
Need more help?
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your
concern with the Office of the Australian Information Commissioner:
• Online: www.oaic.gov.au/privacy
• Phone: 1300 363 992
• Email: firstname.lastname@example.org
• Fax: +61 2 9284 9666
• Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
What additional things do we have to do to manage your complaints about credit
If your complaint relates to how we handled your access and correction requests
You may take your complaint directly to our external dispute resolution scheme or the Office of the
Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to credit information
If you make a complaint about things (other than an access request or correction request) in
relation to your credit information, we will let you know how we will deal with it within seven
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take.
We will also ask you for an extension of time to fix the matter. If you have any concerns, you may
complain to our external dispute resolution scheme or the Office of the Australian Information
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have
any concerns, you may complain to our external dispute resolution scheme or the Office of the
Australian Information Commissioner.
We care about your privacy. Please contact us if you have any questions or comments
about our privacy policies and procedures. We welcome your feedback.
You can contact us by using the details below:
• Who: Sarah Boccaccio
• Phone: 1300 447 026
• Email: email@example.com
• Mail: GPO Box 533, ADELAIDE SA 5001
What if you want to interact with us anonymously or use a pseudonym?
If you have general enquiry type questions, you can choose to do this anonymously or
use a pseudonym. We might not always be able to interact with you this way, however, as we
are often governed by regulations that require us to know who we’re dealing with. In general, we
won’t be able to deal with you anonymously or where you are using a pseudonym when:
• it is impracticable; or
• we are required or authorised by law or a court/tribunal order to deal with you personally.
What do we do with government‐related identifiers?
In certain circumstances we may be required to collect government‐related identifiers such as your
tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change. We will let you know of any changes to this Policy by posting a
notification on our website, or, you may contact us for a copy of the most up to date policy at any time.