Privacy Policy
Our commitment to privacy
We understand the importance of protecting each individual’s right to privacy, particularly that of our Members.
We are bound by, and commit ourselves to compliance with the provisions relating to privacy and to the collection, use and disclosure of personal information set out in:
- The Privacy Act 1988
- The National Privacy Principles set out in Schedule 3 to that Act
- The privacy and confidentiality provisions in the Mutual Banking Code of Practice.
The purposes for which we will collect personal information about individuals
We collect personal information from individuals when they apply for membership and when they apply for or use our products and services. We collect it so we can: - give members information to which they are entitled as a member; and
- supply to members, and administer, the products and services the member requires
- give the member marketing information, unless the member requests us not to.
We also collect personal information from individuals as required by the Anti-Money Laundering and Counter-terrorism Financing (AML/CTF) Act 2006 and we may take steps to verify the personal information we have collected.
How and when we will collect personal information
We will collect the personal information we need about an individual directly from that individual whenever it is reasonable and practicable to do so. We may do so when:
- an individual applies for Membership, applies for any of our products or services, becomes a signatory on an account with us, or offers to give a guarantee in relation to any credit supplied by us
- a Member contacts us in relation to products or services we have supplied to the Member
- an individual contacts us to enquire about Membership or about our products and services, although whenever it is lawful and practicable to do so we will give the individual the option of remaining anonymous.
We may also obtain personal information about an individual who is seeking credit or who has offered to be a guarantor:
- from a credit reporting business or other credit providers, if the individual has given consent in accordance with Part 111A of the Privacy Act 1988
- from a finance broker or a supplier of goods or services who introduces the individual to us, if we are satisfied that the party supplying the information to us has the right to do so and has obtained any necessary consent from the individual.
If an individual is seeking credit we may contact the individual’s employer to confirm that the employer employs the individual.
If a Member has defaulted in repaying credit, we have made reasonable and unsuccessful attempts to contact the Member using the Member’s last known contact details and there are reasonable grounds to believe that the Member has moved without notifying us of the Member’s new contact details, we may contact relatives or friends of the Member to ascertain the Member’s current contact details, or we may retain an enquiry agent to attempt to locate the Member.
We will collect information regarding the operation of a Member’s account when processing transactions conducted on the account.
Our approach to direct marketing
We will inform individuals applying for Membership that we may use personal information about them to send them communications about products and services that we think may be of interest to them and that are available to us and from other businesses. We will give them the option to advise us that they do not wish to receive such communications, and we will advise them that their consent to us using their personal information for this purpose will be implied if they do not notify us that they do not consent.
In all our direct marketing communications to Members we will tell them that they can opt out of receiving any more direct marketing communications. We will not send any direct marketing communications to a Member who has notified us that the Member does not wish to receive such communications.
Contracting out services that involve disclosing personal information
We may give some personal information about Members to other organisations who provide services that assist us in supplying to Members or in administering, the products and services Members require, or assist us in giving Member the information that they are entitled to as Members. Examples of such organisations are our related entities, Credit Union Services Corporation Australia Ltd and its subsidiaries, computer bureaus, printing and mailing houses, insurers, valuers, legal advisors, collection agents and conveyancers.
We will only supply to such an organisation the personal information that is necessary for it to supply the relevant service, and we shall not authorise the organisation to use the information for any purpose other than to provide the service.
Keeping personal information secure
Access to personal information held by us in physical or electronic form is restricted to authorised officers of the Credit Union.
An officer of the Credit Union will only have the level of access rights necessary to enable the officer to perform the officer’s legitimate functions and may only access personal information held by us when it is necessary for the officer to do so to perform such a function.
Personal information that is no longer required by us for any of the purposes for which it was originally collected will be destroyed in a controlled and secure manner.
Access and correction rights
We will, upon request being made in a form acceptable to us, provide an individual with access to the personal information we hold about the individual, except to the extent that:
- in the case of personal information other than health information – providing access would pose a serious and imminent threat to the life or health of any individual
- in the case of health information – providing access would pose a serious threat to the life or health of any individual
- providing access would have an unreasonable impact upon the privacy of other individuals
- the request for access is frivolous or vexatious
- the information relates to existing or anticipated legal proceedings between us and the Member, and the information would not be accessible by the process of discovery in those proceedings
- providing access would reveal our intentions in relation to negotiations with the Member in such a way as to prejudice those negotiations
- providing access would be unlawful
- denying access is required or authorised by or under law
- providing access would be likely to prejudice an investigation of possible unlawful activity
- providing access would be likely to prejudice:
(i) |
the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law |
(ii) |
the enforcement of laws relating to the confiscation of the proceeds of crime |
(iii) |
the protection of the public revenue |
(iv) |
the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct |
(v) |
the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders |
by or on behalf of an enforcement body:
- an enforcement body performing a lawful security function asks us not to provide information on the basis that providing access would be likely to cause damage to the security of Australia.
An individual’s request for access to personal information must be made in writing to our Privacy Officer. It must identify the individual and, with reasonable particularity, the information required. We may require the application to be made using a form supplied by us for that purpose, and we may require evidence of identity to be produced before access is provided.
We may charge individuals reasonable fees, which we will set from time to time, for supplying them with access to their personal information.
We will respond to an individual’s request for access as soon as is reasonably practicable, taking into account the age, nature and amount of information requested.
If we are not required to provide an individual with access to the individual’s personal information, we will:
- if reasonable, consider whether the use of a mutually agreed intermediary is appropriate
- advise the individual the reasons for denial of access.
If an individual claims that personal information we hold about the individual is not accurate, complete, or up to date, then:
- if our Privacy Officer is satisfied that the personal information is not accurate, complete, or up to date, we will correct, complete or update it to the extent that it is reasonably practicable to do so
- if our Privacy Officer is not satisfied that the personal information is not accurate, complete, or up to date, we will, if it is reasonably practicable to do so, include with the information a statement drawing attention to the individual’s claim.
Complaints
Any complaint made to the Credit Union, or to an officer of the Credit Union other than the Privacy Officer, that is related to privacy or to our use of personal information, is to be referred forthwith to the Privacy Officer.
Any Member dissatisfied with the handling of a complaint by the Privacy Officer may make a written request to the Chief Executive Officer. If the complaint cannot be resolved at this level it should be referred to the Financial Ombudsman Service to have the handling of the complaint reviewed. Contact details for the Financial Ombudsman Service are:
Telephone: 1300 780 808 9am - 5pm AEST
Fax: (03) 9613 6399
Email: info@fos.org.au
Mail: Financial Ombudsman Service Ltd, GPO Box 3, Melbourne VIC 3001 |