About this Policy
- Liberty Financial Pty Ltd;
- Liberty Network Services Pty Ltd;
- Secure Funding Pty Ltd;
- Liberty Fiduciary Limited;
- Assured Credit Management Pty Ltd;
- LFI Group Pty Ltd; and
- National Mortgage Brokers Pty Ltd.
When this policy or any of our communications with you about privacy uses the words ‘we’, ‘us’, ‘our’ or ‘ours’ or ‘Liberty Group’, this is a reference to all or any one of these companies.
We may amend this policy from time to time to ensure it remains current. We recommend that you check our website regularly for changes to this policy.
What information do we collect?
We collect and hold personal information about our applicants and potential applicants for our products and services, our customers and business partners. The type of personal information we collect and hold may include but is not limited to:
- identity details such as your name, address, and date of birth;
- contact information such as phone numbers, email addresses and digital handles;
- employment and income information;
- financial information and transactions;
- health information relevant to your products;
- lifestyle information relevant to your products and
- interactions such as those with us, our website or any other communication platforms.
When we act as a credit provider, we participate in the credit reporting system and collect information relating to your credit activities. The type of credit information we collect is explained in the ‘How we participate in the credit reporting system’ section of this policy.
Where do we collect personal information from?
We collect information from you directly when you inquire or apply for a product or service with us and when we speak with you on the phone, exchange electronic and other correspondence, from third party brokers if you use one and from our related companies. We also collect information from credit reporting bodies, other credit providers, our related companies if you have a relationship with them, third parties you have identified in your application to us, such as employers or government agencies and from publicly available sources and any other publicly available information such as information available via social networks.
If you obtain a car loan with us, we may collect information about you from any driver licensing or vehicle registration authority in Australia including but not limited to Roads and Maritime Services (NSW), Department of Transport (WA), Department of Transport and Main Roads (Qld), Department of Planning, Transport and Infrastructure (SA), Road Transport Authority (ACT), VicRoads (Vic), Department of Transport (NT), and Department of State Growth – Transport (Tas).
Why do we collect personal information?
- assessing applications for products and services offered by us;
- managing, varying or enforcing products offered by us;
- letting you know about products and services offered by us or by an organisation that we are associated with that might interest you or meet your financial or insurance needs;
- complying with our legislative or regulatory requirements including but not limited to our requirement to verify your identity;
- research and product development; and
- any purpose related to those other purposes.
In some circumstances we may collect sensitive information about you and your family, for example if you are in default under a loan agreement with us due to ill-health or if you apply for an insurance product. We will only collect personal information from you that is necessary to one or more of our functions and activities.
We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive, such as when you complete an application form or respond to some other communication relating to the management of your relationship with us.
In most cases, it is necessary for us to identify you so that we can provide our products and services. However, if it is lawful and practicable, you may have the option of not providing us with your identity information such as in certain instances relating to general enquiries about products or services.
Once we collect your personal information we will take steps to keep it accurate, complete and up-to-date. Your information will be securely stored in hard copy documents and electronically on our servers and databases as well on the servers and databases of third parties who provide services to us.
How do we use your information?
We will only use your personal information for the purposes we told you it was needed except where: you give us consent to use your personal information for another purpose; the other purpose is related or it is not unreasonable to expect us to use your personal information for that other purpose; it is permitted or required by law; or we reasonably believe it is necessary on health or public safety grounds to use your personal information for another purpose. We will also use your personal information for the purpose of establishing or defending legal claims and as required for alternative dispute resolution proceedings. We will not adopt as our own any government identifiers that you may provide to us such as tax file numbers or Medicare numbers.
We may also use your personal information to send you materials about products or services we think may benefit you. We may also disclose your personal information to our related companies or associated organisations so that they may send you marketing materials. You may tell us at any time that you do not wish to receive any further marketing materials by sending an email to email@example.com and we will stop sending you such materials unless you consent to receiving them again.
Who do we share your information with?
We may share your personal information with our related companies and third parties with whom we have a business relationship including but not limited to:
- our funders, account holders and operators, credit reporting bodies, other credit providers, introducers, valuers, insurers, debt collection agencies, debt administrators and government authorities;
- organisations involved in processing (including card and PIN producers), managing, insuring or funding credit facilities;
- organisations we outsource functions to such as mailing and printing houses and marketing and media organisations including media or social networking sites that provide us with opportunities to place messages in front of you;
- organisations that help us to verify your identity (for example, we may provide your personal information to Equifax, as an authorised Gateway Service Provider of the Document Verification Service, and request that it be matched to information held by the issuer or official body that records that information);
- organisations that provide verification of your income or employment;
- specialist advisers such as accountants and solicitors (both yours and ours); and
- our associated organisations so that they may let you know about products and services which might meet your needs.
You should be aware that some of the recipients of your information may not have privacy practices equivalent to ours.
Do we send your information overseas?
We will endeavour not to send your personal information overseas. However there may be circumstances where it is necessary to do so, such as when we share your information with our service providers who use cloud servers located overseas to store your information, or our related entities overseas perform operational or administrative services on our behalf, for example.
Unless the other country has privacy laws which are substantially similar to our own or where we are required to disclose your information by law, we will seek your consent before we send your information overseas. The countries we may send personal information to include New Zealand, the United States, England or countries in the European Union.
How can you access your information?
You may request access to your personal information at any time. We will respond to you within 30 days of receiving your request.
In most cases we will facilitate access by providing you with copies of or a summary of relevant documents. However we may decide that other means of providing you with access are more appropriate based on the circumstances of your request. In most cases, we will charge you a fee of $50 for providing you with access to this information.
We are not required to provide you with access to your personal information in certain circumstances, such as where your request is frivolous or vexatious, or where providing access would unreasonably interfere with another person's privacy, would be a breach of the law, or where the information you request is not relevant, commercially sensitive or relates to existing or anticipated legal proceedings. If we refuse access we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint.
What if your information is inaccurate?
If you request, or if we believe that the personal information we hold about you is inaccurate, out-of-date, incomplete or misleading, we will take reasonable steps to correct your information. We will respond to your request for correction within a reasonable period of receiving your request. We will not charge you for making a request if we correct your information.
If we have previously disclosed your personal information to another entity, you may ask that we notify the other entity of the correction. We will notify the particular entity you have identified in your request provided it is not impracticable or unlawful for us to do so.
If we refuse correction we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint. If we refuse to correct your personal information, you may request that we associate your information with a statement that the information is inaccurate, out-of-date, incomplete or misleading. We will take reasonable steps to associate the statement in an appropriate way.
You may make a request for access or correction by contacting our Privacy Officer using the details below.
How do we protect your information?
We take steps to protect personal information from misuse, interference, loss and unauthorised access. Some of these steps include physical security such as locks and access control to our premises and computer security including requiring passwords and other security measures for accessing our systems and databases, as well as having information security policies that our staff and business partners must follow.
You can also help us keep your personal information secure by ensuring that any password you use to access our systems is kept strictly confidential and by logging off when you have finished using a shared computer. We will not be responsible for any access or change made to your personal information occurring as a result of you disclosing your password to a third party or through any unauthorised access.
How we participate in the credit reporting system
If you apply for a product with us, we will generally collect information about you from credit reporting bodies. The type of credit information we collect includes but is not limited to:
- identification information such as your name, address, date of birth and employment details;
- default information if you have defaulted in your payment obligations to us or other credit providers or committed a serious credit infringement and information about any subsequent payments or new credit arrangements you enter into;
- consumer credit liability information, including details about credit you have with us and other credit providers;
- repayment history information such as when and how you meet your monthly payment obligations to us and other credit providers; and
- information relating to court proceedings or personal insolvency proceedings and other information relating to your credit history.
When we disclose credit information about you to credit reporting bodies, this credit information may be included in a credit report that credit reporting bodies provide to other credit providers to assist them assess your suitability for their products and services.
We may use any of Equifax Pty Limited (Equifax), Experian Australian Credit Services Pty Ltd (Experian), Illion (formerly Dun & Bradstreet), Tasmanian Collection Service (TCS), Equifax New Zealand as the credit reporting body or bodies from whom we collect and to whom we disclose credit information from time to time. They may be contacted as follows.
|Credit Reporting Body||Contact Details||Credit Information Policy|
|Equifax and Equifax NZ||www.mycreditfile.com.au
You have the right to contact any of these credit reporting bodies and request that they do not use your information for marketing and related purposes. If you reasonably believe that you have been or are likely to be a victim of fraud, you may contact the credit reporting body and request that they do not use or disclose your information.
Making a complaint
We are committed to providing applicants, customers, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints.
If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the points referred to in this policy. We will seek to address any concerns that you have through our complaints handling processes and in most cases will respond within 30 days of receiving your complaint.
If we are unable to resolve your complaint to your satisfaction you may refer your concerns to the Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC).
How to contact our Privacy Officer
How to contact the AFCA
How to contact the OAIC