Credit Information Management Policy

Privity Pty Ltd t/as Haircare Group 

1. Purpose and Application 

1.1. Privity Pty Ltd (ABN 23 007 887 729) trading as Haircare Group (Haircare Group) is bound by the Privacy Act 1988 (Cth) (as amended from time to time) (Privacy Act) and the Credit Reporting Privacy Code (CR Code) in relation to the way that Haircare Group handles credit information.  The Privacy Act and CR Code regulate the manner in which Haircare Group can handle certain types of credit information and how Haircare Group must respond to requests to access and correct credit information. 

1.2. Haircare Group views any breach of privacy protection as serious, and will take appropriate action in such cases. 

1.3. This Policy sets out Haircare Group's credit information handling procedures and the rights and obligations that both you and Haircare Group have in relation to your credit information. 

1.4. This Policy applies to the extent that Haircare Group is a credit provider for the purposes of the Privacy Act.  Haircare Group's general information privacy policy is available here.  Haircare Group's Terms and Conditions are available here. 


2. What is credit information? 

2.1. Credit information is personal information that is related to credit that you have applied for or which has been provided to you such as your contact details, information about your credit accounts, and any default and payment information. 

2.2. Credit eligibility information includes the credit information listed above, as well as: 

(a) information disclosed to Haircare Group by a credit reporting body; and 

(b) information Haircare Group derives about you from conducting its own analysis of information reported back to Haircare Group by a credit reporting body. 

2.3. Credit reporting information is information derived by a credit reporting body from your credit information, which may include an assessment of your credit worthiness and your eligibility for consumer credit. 


3. What kinds of credit information does Haircare Group collect and how does Haircare Group collect it? 

3.1. Specific kinds of credit information and credit eligibility information that Haircare Group collects and holds may include: 

(a) your identification information, including your name, date of birth, drivers licence details, postal and residential addresses, telephone and facsimile numbers, and email addresses; 

(b)  information about your financial circumstances required to assess applications for credit, for example, your income, your expenses, your savings and assets and liabilities; 

(c) information about credit you might have; 

(d)  specific financial information, including various account details and superannuation details; 

(e) details of enquiries made about you by other credit providers or insurers; 

(f)  details of new arrangements to vary or refinance other consumer credit; 

(g) opinions from other credit providers as to whether you have committed serious credit infringements; 

(h) details about your credit worthiness, for example, other credit you might have or have applied for, information relating to court proceedings, and details from the National Personal Insolvency Index; and 

(i) information about your repayment history, and whether you have had any overdue payments or defaults. 

3.2.  Haircare Group collects credit information and credit eligibility information about you if you apply for credit or give a guarantee.  Haircare Group may collect credit information from you if you provide it to Haircare Group in person, or if you complete an Application for Credit Account. 

3.3. In the course of operating its business, Haircare Group may also collect credit information from third parties such as: 

(a) credit reporting bodies, for example, a credit report; 

(b) other credit providers, for example, opinions about your credit worthiness; 

(c) public registers or other publicly available sources of information; 

(d) your personal representatives, which may include other financial advisors, an administrator, or a solicitor; and 

(e) Haircare Group's service providers, contractors, suppliers or business partners. 

3.4. If you choose not to give Haircare Group any credit information that it requests from you, Haircare Group may not be able to approve your application for credit, or provide you with any goods or services you have asked it to supply. 


4. Purposes for which Haircare Group collects, holds, uses and discloses credit information 

4.1.  Haircare Group will generally collect, hold, use and disclose credit information and credit eligibility information for the following purposes: 

(a) assessing an application for credit and determining your eligibility for credit; 

(b) assessing whether to accept an individual as a guarantor; 

(c) ongoing management of your Credit Account, including, where relevant, by providing you notice to avoid defaulting on your obligations; 

(d) internal management purposes directly related to the provision or management of credit; 

(e) collecting payments that are overdue in relation to commercial credit; 

(f) informing you about products or services that Haircare Group thinks may be of interest to you, subject to complying with legal restrictions on using credit information and credit eligibility information for marketing purposes; 

(g) participating in an external dispute resolution scheme; 

(h) assisting Haircare Group to collect any overdue payments; and/or 

(i)  investigating whether an individual has or has attempted to fraudulently evade obligations in relation to consumer credit. 

4.2. By providing Haircare Group with your credit information, or by requesting credit from Haircare Group, you consent to Haircare Group collecting, holding, using and disclosing your credit information and credit eligibility information for the above purposes. 

4.3. You can opt-out of receiving marketing materials from Haircare Group by contacting Haircare Group's Privacy Officer.  You may also opt out of your credit information being used by credit reporting bodies to pre-screen for direct marketing purposes. 

4.4. Haircare Group may also use or disclose credit information where Haircare Group is authorised or required by law to do so. 

4.5. The types of third parties to whom Haircare Group may disclose your credit information and credit eligibility information include, but are not limited to: 

(a) Haircare Group's related bodies corporate; 

(b) Haircare Group's contractors and service providers, for example, persons who process applications for credit or manage the credit Haircare Group provides, or technical or support services; 

(c) Haircare Group's suppliers, for example, insurers; 

(d) professional advisors, for example, legal advisors; 

(e) representatives who sell Haircare Group's products and services on its behalf; 

(f) other financial institutions, including credit providers; 

(g) other credit providers if Haircare Group is acting as agent for that credit provider or otherwise, with your consent; 

(h) potential guarantors; 

(i) credit reporting bodies; and 

(j) debt collection agencies. 

4.6. Haircare Group holds all applicable types of credit information as physical records, records on Haircare Group's servers, and in some cases, records on third party servers, which may be located overseas. 

4.7. Haircare Group takes active steps to hold all hard copy and electronic records of personal information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure. 

4.8. Haircare Group has procedures in place to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law. 


5. Notifications 

5.1. When Haircare Group collects credit information from you, it  will take reasonable steps to notify you or ensure that you are otherwise aware of: 

(a) the fact that Haircare Group has collected your credit information, and whether that collection is required or authorised by law; 

(b) the purposes of collection; 

(c) the consequences if credit information is not collected (such as if this will affect Haircare Group's ability to provide products or services to you); 

(d) the usual situations in which we disclose credit information of the kind collected; 

(e) information about this Policy, in particular how it contains information about accessing and correcting the credit eligibility information held by Haircare Group, and Haircare Group's complaint procedures; and 

(f)  whether Haircare Group is likely to disclose credit information or credit eligibility information to entities that do not have an Australian link, and the relevant countries in which such entities are located. 

5.2 Some of the above information is included in this Policy. 


6. Cross border disclosures of information 

6.1. As at the date of this Policy, Haircare Group is not likely to disclose credit information or credit eligibility information to any overseas entities that do not have an Australian link. 

6.2 . If in future Haircare Group proposes to disclose credit information or credit eligibility information to such entities, it will do so in compliance with the requirements of the Privacy Act. 


7. Credit Reporting Bodies 

7.1. Haircare Group may provide your credit information to, or collect your credit reporting information from, a credit reporting body. As at the date of this Policy, the credit reporting body that Haircare Group deals with is Illion. The contact details for Illion are set out below: 

Mailing Address: PO Box 7405, St Kilda Road, Melbourne VIC 3004 
Address: Office l2/479 St Kilda Road, Melbourne VIC 3004 
Telephone: 03 9828 3333 

7.2 . Please note that the credit reporting body may include the information in reports provided to other credit providers to assist them to assess your credit worthiness.  Further, if you fail to meet your payment obligations in relation to consumer creditor you commit a serious credit infringement, Haircare Group may be entitled to disclose this to the credit reporting body. 

7.3. You are entitled to request directly from the credit reporting body: 

(a) the credit reporting body's credit information management policy; 

(b) that it not use your credit information for the purposes of pre-screening of direct marketing by another credit provider; and 

(c) that it not to use or disclose your credit information, if you believe on reasonable grounds that you have been, or is likely to be, a victim of fraud. 


8. How can you access and correct your information? 

8.1. You have a right to request access to your credit information and credit eligibility information and to request its correction if it is out of date or incorrect.  You may do so at any time by sending a written request to Haircare Group's Privacy Officer using the contact details set out at the end of this Policy. 

8.2. You do not need to provide a reason for your request for access to your credit information and credit eligibility information.  Haircare Group may charge a small fee for providing access to information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form. 

8.3.  Haircare Group will respond to all requests for access to or correction of credit information and credit eligibility information within 30 days of the request. 

8.4. Please note there may be circumstances in which Haircare Group cannot provide you with access to your information, such as where the requested access will have an unreasonable impact upon the privacy of others or where Haircare Group is required by law to withhold the information.  If Haircare Group is unable to provide you with access to your information, or make the amendments which you have requested, Haircare Group will provide you with reasons for this decision. 


9. Enquiries and complaints 

9.1. If you have a question about this Policy or you believe that Haircare Group has not complied with Part IIIA of the Privacy Act or the CR Code, please direct your concerns/query to Haircare Group's Privacy Officer using the contact details set out at the end of this Policy. 

9.2. Haircare Group takes all complaints seriously.  Within 7 days of your complaint, Haircare Group will provide you with a written notice acknowledging your complaint, and setting out how it will deal with your complaint.  Haircare Group will make a final decision in respect of your complaint within 30 days from the date of your complaint, or as otherwise agreed with you.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner: 

Office of the Australian Information Commissioner:

GPO Box 5218 
Sydney NSW 2001 
Telephone: 1300 363 992 

Visit the Office of the Australian Information Commissioner website for further information. 

9.3. General 

This Policy reflects Haircare Group's Credit Information Management Policy as at 25/06/2019 and replaces all previous Credit Information Management Policies.  Haircare Group will review this Policy from time to time, and incorporate amendments in the updated Policy.  The amended Policy will be published on this website. 

Haircare Group's Privacy Officer can be contacted as follows: 

Privacy Officer 
Haircare Group 
17-21 commercial st 
SA 5033 

Phone: +61 8 8403 8282 
Fax: +61 8 8403 8210