Privacy

Review Keystart's privacy policy statement.

Keystart's Privacy and Credit Reporting Policy ('Policy')

How we handle your information

1. About Keystart and this policy

Keystart is committed to protecting the privacy and security of your personal information including your credit information.

In this policy, 'We', 'Keystart Group', 'us' and 'our' refer to Keystart Loans Ltd ACN 009 427 034 in its own right and as trustee for the Keystart Housing Scheme Trust (Keystart) and Keystart Scheme Management Pty Ltd ACN 120 164 847.

This policy explains how we protect, collect, store, use and disclose your personal information (including credit information). We are bound by the Privacy Act 1988 (Cth) (Privacy Act), including Part IIIA of the Privacy Act and the Australian Privacy Principles contained in the Privacy Act, as well as the Privacy (Credit Reporting) Code 2014 (CR Code).

Sometimes we update our privacy policy. You can always find the most up-to-date version on our website.

2. What information do we collect?

We collect personal information including credit information.

What is personal information and what kinds of personal information do we collect?

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, whether recorded in a material form or not, about an individual whose identity is apparent, or can be reasonably ascertained, from the information or opinion.

Personal information we collect may include:

information about your identity — your name, address, contact details, date of birth, gender,
marital status, dependants and occupation;
Government-issued identifiers such as your driver’s licence number;
sensitive information such as health information;
financial and transaction information;
information about your payment of rates over a property you have given us security over; and
employment details; and
call recordings.

The personal information we collect about you may also include credit information (which is described further below).

The personal information that we collect about you will depend on the loan type that you apply for or enquire about. Keystart will only collect personal information that is relevant to your loan application or that is necessary for the ongoing management and administration of your loan.

Call recordings

We may monitor and record our calls with you. We will notify you when we are doing this. Your call recordings may contain personal information (including sensitive information).

What is sensitive information and what kinds of sensitive information do we collect?

Sensitive information is a subcategory of personal information. It includes health information and information about your ethnicity. Under the Privacy Act, sensitive information can only be collected when we have your express consent or in certain other permitted situations. We generally only collect sensitive information if:

it is required by law;
you are applying for a specific loan product where the sensitive information is relevant to your eligibility for that product (for example, we collect information about your ethnicity if you are applying for an Aboriginal Home Ownership Scheme loan and information about your disability if you are applying for an ACCESS Home Loan); or
it is relevant to a hardship application you have made.

What is credit information and what kinds of credit information do we collect?

Credit information is personal information that, in broad terms, relates to the credit that has been provided to you or that you have applied for. It includes information supplied to us by a credit reporting body, and any information that we derive from it.

When you apply for a loan, we will obtain a credit report which contains information about your credit history. A credit report contains information which assists us to assess your application, including information about your credit history with other credit providers. Credit reports are designed to assist credit providers to accurately assess an individual's ability to repay credit.

We also collect other credit information about your financial position including:

information about your employment, income and expenses; and
your dealings with other credit providers, including information about any serious credit infringements that you may have committed.

3. How do we collect personal information (including credit information)?

We usually collect personal information directly from you or from a person that you have authorised to give your information to us. We collect this information when you interact with us – for example where you:

apply for, register your interest in, or enquire about our products or services;
provide us with feedback or make a complaint;
talk to us, or do business with us;
visit our website; or
make transactions in connection with the credit provided by us, such as when you make repayments to us.

When you interact with us on our website, we may also collect some personal information using cookies (for more information please see our Electronic Platform Terms and Conditions).

We may also need to collect personal information (including credit information) about you from third parties, such as:

other credit providers or financial institutions such as banks;
credit reporting bodies;
any person or body who may provide reports on your commercial activities and your commercial credit worthiness;
your representatives such as financial advisers, accountants or your insurers;
your employer;
publicly available sources of information;
any local government office or other government authority; and
any person or body referred to in your loan application.

4. Why we collect personal information

The main reason we collect, hold and use personal information (including credit information) is to provide you with products and services, and to assist us in managing our business. As part of this, we collect, hold and use your personal information in order to:

assess your loan application;
contact you and otherwise manage our relationship with you;
fulfil our obligations under relevant laws, regulations, codes of practice or in relation to payment systems, including the National Consumer Credit Protection Act 2009 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
maintain and monitor loans over the term of that loan;
provide statistical data to members of the Keystart Group;
monitor and evaluate our products and services;
gather and aggregate information for statistical, prudential, actuarial and research purposes;
maintain our internal operations, including record keeping, risk management, auditing purposes, transactions, credit scores and file reviews;
take measures to detect and prevent frauds and credit loss;
determine whether you need assistance to meet your repayment obligations;
determine if you are meeting your payment obligations to local government offices or other
government agencies and authorities;
monitor, resolve and prevent complaints you may raise against Keystart or to manage legal action
between you and Keystart;
market our products and services (as described in the ‘Direct Marketing’ section below); and
any additional purpose which we inform you about or which you have agreed to.

The Privacy Act and the CR Code limit what we can do with the information we obtain from a credit reporting body. It can usually only be used in relation to consumer credit products you have with us.

Direct Marketing

We may use your personal information to let you know about new or existing products or services that we think might be of interest or value to you. We may provide your personal information to third parties that provide direct marketing services for Keystart.

To do this, we may contact you by email, phone, SMS, social media, mail, Keystart and third-party apps or Keystart or third-party websites.

We will not send you direct marketing messages if you inform us that you do not want to receive them. You can opt-out or change your marketing preferences by:

calling us on 1300 578 278;
in the case of direct marketing emails, using the ‘opt-out’ facility included in the email; and
logging into Keystart Customer App and changing your marketing preferences under the “More” option.

We will not use any information that we have received from a credit reporting body for marketing purposes. However, for some products, Keystart may ask a credit reporting body to use the credit reporting information they hold to identify individuals that are eligible for a Keystart marketing offer.

If you are eligible, you may be sent an offer on Keystart’s behalf. See the 'Sharing credit information' section for information about how you can contact the credit reporting body if you do not want them to use your information in this way.

5. What happens if you do not provide us with the information we request?

If you do not provide us with the personal information that we reasonably request, Keystart may be unable to provide you with a loan or to provide other services to you.

6. Who do we share your information with?

Keystart may share your personal information (including credit information) with the entities in the Keystart Group.

We may also share this information with people and organisations outside of the Keystart Group where that third party assists in relation to the establishment or administration of your loan or supports the provision of services to you. We only provide these third parties with the information needed to provide the service or comply with the law.

The types of third parties that we may share your personal information (including credit information) with include:

our agents, contractors and contracted service providers such as mailing houses, data processors, technology service providers, researchers and debt collectors;
other financial services organisations, including banks;
our professional advisers such as our legal advisers, financial advisers and auditors;
insurers and re-insurers;
valuers;
credit reporting bodies and credit providers;
Housing Authority (if you have a Shared Ownership Home Loan);
regulatory bodies, government agencies and authorities, local government offices, courts and external dispute resolution schemes;
organisations that are considering purchasing or that purchase your debt or organisations to
which we are considering assigning or to which we have assigned our debt;
to a co-borrower (if any);
any person who introduces you to us;
your land developer and builder (if you applied for a construction loan);
your representatives, such as mortgage brokers and their aggregators, finance brokers, settlement agents, real estate agents and other intermediaries; and
your next of kin (if required).

We may also share your personal information (including credit information) with third parties where:

it is permitted or required by the law;
you provide your express consent to the disclosure or your consent may be reasonably inferred from the circumstances; or
privacy laws otherwise allow us to disclose the information.

Sending information overseas

Some of the parties with which we share your personal information (including credit information), such as our contracted service providers, are located or operate outside of Australia. The countries where we are likely to disclose personal information are European Union (EU) countries and the United States of America. Where we send information overseas, we ensure there are arrangements in place to protect your information.

Sharing credit information

Keystart participates in Comprehensive Credit Reporting (CCR). We exchange certain information with credit reporting bodies.

If we are requesting a credit report about you from a credit reporting body, we may provide the credit reporting body with:

information about you (for example, your name and address); and
information about your application (such as the amount of credit you are applying for).

If you receive a loan from us, we will provide certain information to the credit reporting body as part of CCR including:

that we provide credit to you,
the type of credit that you hold,
how much credit we have provided to you,
the terms and conditions of the provision of that credit,
when your credit account is opened and closed,
how you repay your credit,
if you have failed to meet your repayment obligations or defaulted on your obligations,
any financial hardship information and financial hardship arrangements in relation to your account/s;
if you have committed a serious credit infringement,
if you make repayments on time, and
if you correct a default.

You should be aware that:

credit reporting bodies may include the information we provide to them about you in reports provided to other credit providers to assist them to assess your creditworthiness;
you can request a credit reporting body not to use your credit reporting information for the purposes of pre-screening of direct marketing by us. The contact details for Equifax are set out below, and
you can request a credit reporting body not to use or disclose your credit reporting information for a period if you believe on reasonable grounds that you have been (or are likely to be) a victim of fraud. The contact details for Equifax are set out below).

The credit reporting body we exchange information with is Equifax.

Equifax can be contacted by post, phone, email or online using the contact details set out below:

Equifax Australia Information Services and Solutions Pty Limited
PO Box 964
North Sydney NSW 2059
Telephone: 13 83 32
Email: customerserviceau@equifax.com
Web: mycreditfile.com.au

A copy of Equifax’s privacy policy is available at www.equifax.com.au/privacy and its credit report policy is available at www.equifax.com.au/credit-reporting-policy

7. Accessing and seeking correction of your information

We take reasonable steps to make sure that the personal information (including credit information) that we collect, use or disclose is accurate, complete and up to date.

You can request access to and ask that we correct the personal information (including credit information) we hold about you. There is no fee for requesting a correction to your personal information or for us to make corrections. There may be a reasonable charge for giving you access to your personal information to cover our costs for locating and giving this information to you (but there is no fee for simply making the request).

Requests for access and correction to your personal information can be made by post or email at the following details:
Email: privacy@keystart.com.au
Mail:
Attention: Privacy Team
Keystart
PO Box 2016
Subiaco WA 6904

If you have requested access to your personal information, the Privacy Team will then contact you to verify your identity and advise you of the timeframe for collecting or viewing your personal information and any associated fee (which must be paid before the information is provided to you). Once your information is available, we will contact you to agree on a way for you to access your information.

There are certain circumstances where the law permits us to not provide you access to certain personal information that we hold about you. For example, we do not need to provide you access to your personal information where:

we reasonably believe that giving access would pose a threat to the life or health of anyone;
giving access would have an unreasonable impact on the privacy of another person;
the information relates to anticipated or actual legal proceedings (and would not be accessible by the process of discovery);
giving access would be unlawful; or
giving access would reveal information generated in connection with a commercially sensitive decision-making process.

If we refuse to give you access to or to correct your personal information, we will give you notice:

explaining the reasons for our refusal (except where it would be unreasonable for us to do so); and
providing information about how you can complain about the refusal.

If we refuse your request to correct your personal information, you can request that a statement be linked with your personal information noting that you do not agree with the accuracy of the information.

If you believe that any personal or credit-related information that Keystart holds about you is not accurate, complete or up to date, you should notify the us in writing as soon as possible.

8. Protecting your information

Your personal information (including credit information) is kept in both hard copy and electronic form. We may use cloud storage to store the personal information we hold about you.

The electronic information is stored in secure monitored storage areas located in Australia, EU Countries and the United States of America (including storage areas owned and operated by our contracted service providers).

We use a range of security measures to protect the security and confidentiality of your personal information. These measures include the following:

computer access can only be gained through a combination of user ID and password;
passwords are automatically changed at frequent intervals to help prevent unauthorised access;
where software support service providers require access to these systems for software maintenance, access is only permitted after proper authorisation;
employees are bound by Keystart’s Acceptable Use Policy and other associated policies when hired;
the use of encryption to protect information when storing and transmitting data;
the performance of background checks, including police clearance checks, for all personnel and
contractors engaged by Keystart;
assessing new third party vendors that may handle or process personally identifiable information to ensure any privacy and security risks are identified and managed appropriately; and
external and independent testing of systems to identify security risks (if any), to facilitate appropriate management.

When we no longer require your personal information (and are no longer required by law to keep it) we take reasonable steps to destroy or permanently de-identify it.

Although we take reasonable measures to protect your personal information, no data transmission over the internet can be guaranteed to be fully secure. Please contact us immediately if you think that your interaction with us is no longer secure.

9. Making a privacy complaint

If you have a query or complaint regarding how your personal information is being handled by us
(including about a breach of the Australian Privacy Principles or an applicable code), you can contact
Keystart by:

speaking to our customer service team on 1300 578 278 or (08) 9338 3151;
emailing our Privacy Team at privacy@keystart.com.au;
via the online form available at keystart.com.au/contact-us; or
by mail addressed to:

The Complaints Manager
Keystart
PO Box 2016
Subiaco WA 6904

Credit information complaints

If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. We will let you know we have received your complaint within seven days of receipt of your complaint. If we cannot resolve your complaint within 30 days, we will get in touch to tell you why and agree a new timeframe with you.

What else can you do?

If you are not satisfied with how we have managed your complaint or our decision after you have been through our internal complaints process, the Australian Financial Complaints Authority (AFCA) offers a free independent dispute resolution service for consumer and small business complaints. Before AFCA can investigate your complaint, they generally require you to have first provided us with the opportunity to address the complaint (see the section titled ‘Making a privacy complaint’ for details of how you can lodge your complaint with Keystart).

You can contact AFCA between 9am and 5pm (Sydney time) Monday to Friday using the contact details set out below.

AFCA can consider most complaints involving financial services providers.

If your complaint is about how we handle your personal information, you can also contact the Office of the Australian Information Commissioner (OAIC) using the contact details set out below. The OAIC requires you to first make your complaint to us. We have 30 days to deal with your complaint before you are able to make a complaint to the OAIC.

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Phone 1800 931 678 (free call)
Email info@afca.org.au
Visit afca.org.au

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone 1300 363 992
Email enquiries@oaic.gov.au
Visit oaic.gov.au