Complete Credit Solutions and all related entities are committed to protecting your privacy, confidentiality, security and integrity of your personal information held by us. As part of that commitment we aim to comply fully with the National Privacy Principles for the fair handling of personal information, as set out in the Privacy Act 1988 (Cth) (”the Act”) as amended by the Privacy Amendment (enhancing Privacy Protection) Act 2012 in relation to its activities in Australia, the Australian Privacy Principles and the Credit Reporting Privacy Code (CR Code).
“Personal information” means information or an opinion about an identified individual, or an individual who is identifiable, whether the information is true or not, and whether the information is recorded in material form or not.
How is your personal information collected?
We collect your personal information when we perform debt collection services for ourselves and our clients. Where reasonably possible, we shall collect personal information directly from you. If we are unable to collect personal information from you, other sources which Complete Credit Solutions collects your personal information include:
- Credit Reporting Agencies;
- The credit provider(s) who assigned your account(s) to us
- Our clients who appointed us to collect debts on their behalf
- Any third party who we believe may be able to assist us in making contact with you (where you have not been readily contactable directly); including family members, friends, colleagues or referees.
- Publicly available sources of information or databases subscribed to by Complete Credit Solutions such as people search databases, property and tenancy databases
- Any third party authorised by you to be your representative;
What personal information is collected by Complete Credit Solutions?
We will only collect your personal information where it is reasonably necessary in connection with the services we are providing you. The types of personal information we will collect include:
- Your name, date of birth, residential and postal address, contact numbers, email addresses, employment details
- Your personal information and credit information held with various credit reporting agencies such as:
- your repayment history and any defaults
- credit requests (including amount and type) you have made to other credit providers; or
- variations to credit arrangements following a default;
- court proceedings and personal insolvency; or
- the opinion of credit providers about credit infringements committed by you;
- Sensitive personal information (such as criminal records, personal health information or membership of a professional or trade association/union) which we have collected with your consent.
We may also monitor telephone conversations for training and quality purposes. Please inform the operator if you do not wish your call to be monitored. When a call is monitored it may be recorded. Any recorded calls are only retained for training and quality purposes.
How does Complete Credit Solutions use your personal information?
Complete Credit Solutions uses your personal information for the following purposes:
- To comply with legal or regulatory requirements or as authorised by legal or regulatory requirements, including under the Anti-Money Laundering and Counter–Terrorism Financing Act 2006 (Cth), Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007;
- For compliance, quality assurance and staff training purposes, for example when we communicate with you through phone calls, we may record the telephone conversation for this purpose.
- To assess your credit worthiness;
- To allow us to appropriately manage your account, which includes identifying you and arranging for payment of the outstanding balance on your account;
- To conduct checks with credit reporting agencies such as Veda Advantage, Dun & Bradstreet and Experian;
We will generally not use or disclose your personal information for any other purpose without your consent, but may do so in certain circumstances where:
- It is sufficiently related to an activity described above and you would reasonably expect us to use or disclose your personal information for that purpose;
- Required in connection with a confidential alternative dispute resolution process and we reasonable believe it is required for enforcement related activities of an enforcement body
- It is connected with an entity subject to the Act to locate a person who has been reported as missing;
- Required to establish, exercise or defend a legal or equitable claim;
- We suspect you have engaged in unlawful activities or serious misconduct and the use or disclosure of your personal information is required for us to take appropriate action in relation to the matter;
Disclosure of information
In the course of our business, we may disclose your personal information to our associated companies, outsourced service providers, our clients whom refer us work. We may also disclose your personal information to:
- A credit reporting agency, in any manner that is permitted under the Act, and the CR Code
- The credit provider who assigned your account(s) to us;
- Our accountants, auditors, lawyers
- Your representatives (authorised party, lawyer, financial adviser, executor, administrator or trustee);
- Any person to whom such disclosure is required by law or regulatory requirement or pursuant to a court order;
- Our service providers, agents or contractors appointed to provide services to Complete Credit Solutions or its related, associated or affiliated companies.
- Parties where you have given your consent.
In respect of our dealings with credit reporting agencies/bodies it is important to note that:
- Personal information you provide may be included in reports to other credit providers to assist them to assess your credit worthiness;
- That if you fail to meet your payment obligations in relation to consumer credit or you commit a serious credit infringement, we may be entitled to disclose that to credit reporting agencies/bodies;
- You may request that credit reporting agencies do not use their credit reporting information for the purposes of pre-screening direct marketing by another credit provider; and
- That credit agencies do not use or disclose credit reporting information about you, if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
Credit reporting agencies/bodies will generally only be provided with information regarding your identification, credit worthiness, the credit product held or being sought, your repayment history, any defaults and any serious credit infringements committed by you ( such as fraudulently trying to either obtain credit or evade your obligations in respect to that credit). In the event we disclose default information about you to a credit reporting agency, we will advise that credit reporting agency when you have fully discharged the default amount.
How we hold your personal information
We understand that the security of your personal information is important to you so we take steps to protect your personal information from misuse, interference, loss and from unauthorised access, modification or disclosure. Access to your personal data by our employees, service providers, agents or contractors is strictly on a need-to-know basis. The personal data collected will be retained by Complete Credit Solutions for the duration or required by law. If specific personal information is no longer needed, we will take steps to destroy the information or ensure the information is de-identified.
Accessing your personal information
You can request to access your personal information by contacting us below but will be required to provide a copy of your drivers licence or another form of government identification document to confirm your identity. No fee is charged for lodging a request for access. In some cases we may charge a reasonable fee to provide access to your personal information but we will advise you before we provide access if there is a fee payable.
In certain circumstances set out in the Privacy Act 1988 you will not be able to access your personal information, for example when:
- The information is relevant to legal proceedings between us and could not be obtained by you through the discovery process for those proceedings;
- Disclosure would be unlawful;
- We reasonably suspect you have engaged in unlawful activity or serious misconduct relating to our activities and giving access would prejudice our ability to take appropriate action in respect of your conduct;
- Or granting access would prejudice one or more enforcement related activities conducted by an enforcement body.
- If we do not grant you access to all or some of your personal information we will provide you with a written statement explaining why we denied your request for access.
Seeking correction of your personal information
We will take reasonable steps to ensure that your personal information is accurate, up-to-date, complete, relevant and not misleading. If you believe the personal information we hold about you is not correct, please contact us. We will provide you with a copy of your personal information within a reasonable period after the request is made, usually within 30 days.
If we are unable to correct your personal information, we will advise you of this in writing and provide a reason.
Making a complaint
If you have any concerns about how we have managed your personal information, you can:
- Speak with the account manager who is managing your matter; or
- Request to speak with a manager or our Internal Dispute Resolution team at anytime; or
- Contact the relevant External Dispute Resolution scheme (if applicable); or
- Contact the Office of the Australian Information Commissioner.
Internal Dispute Resolutions – Contact Details
External Dispute Resolution Scheme
Australian Financial Complaints Authority (AFCA)
The office of the Australian Information Commissioner