Australian Receivables Limited (ACN 103 234 653) (ARL) takes our obligations to protect personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) seriously.
· the kinds of personal information we collect and hold about you;
· how we collect your personal information;
· how we hold your personal information;
· the purposes for collecting, holding, using and disclosing your personal information;
· how you may access your personal information held by us and if that information is incorrect how you may get it corrected;
· how you may make a complaint about the way we collect, hold, use or disclose personal information, and how we will deal with Privacy complaints;
· whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located.
The interaction we have with you will be specific to an account and relate to your personal information so we need to identify you before we can engage in further discussions and correspondence. You will not be able to interact with us anonymously or by using a pseudonym unless the interaction is a general inquiry only and does not in any way relate to an account.
We will not adopt, use or disclose any tax file number, pension number, Medicare number or any other government agency identifier as an account number, but we will assign an ARL reference number. We will ask for the ARL reference number every time we interact with you and we will ask you to confirm your personal information before discussing an account with you.
Your personal information will not be used for the purpose of direct marketing.
This Policy will be kept up to date and published on the ARL website.
The kinds of personal information we collect and hold about you
ARL is a debt collection agency. We collect personal information from our clients, service providers, field agents, public records, customers and authorised representatives.
The type of personal information we collect and hold may vary depending on the nature of our interactions and the business we deal with and will include your name and contact details and may financial information, credit related information, transaction and repayment history information, banking details, employment information, health informationand other identification information.
ARL will collect and hold name and contact information of all individuals we deal with together with any of the above types of information which are reasonably necessary to provide our services. In order to satisfy our legal obligations, we may need to retain your information after a transaction or interaction has ended. However, we will not retain your identifiable personal information longer than is reasonably necessary and permitted under Australian law.
We will only collect sensitive information with your consent or when permissible under Australian law and will only use this information for a legitimate purpose where this is reasonably necessary.
How we collect your personal information
Your personal information is collected from our clients and the businesses we deal with. During our interaction with you we will confirm the personal information is correct directly with you. This may be over the telephone, by e-mail, by SMS, over the internet, by mail or fax, or by completion of a form (e.g. a Statement of Position (SOP form).
In addition to personal information provided by our clients or that held in public records we may also collect your personal information from a third party. This will be in circumstances where it is impracticable for us to collect it directly from you. The type of third party who might provide information to us will vary depending on the nature of the business we deal with and interaction we have with you. It could include:
· a credit provider;
· someone authorised to act on your behalf,
· third party service providers and/or suppliers;
· field agents;
· a solicitor;
· an employer;
· a government body;
· a credit reporting bureau.
How we hold your personal information
We understand the importance of protecting the personal information we hold about you and have taken steps to ensure your personal information is free from misuse, interference, loss, unauthorised access or modification by:
· securing all personal information;
· limiting access to personal information only to those that need access; and
· protecting our systems with appropriate technology solutions.
The purposes for collecting, holding, using and disclosing your personal information
We collect, hold, use and disclose your personal information for the lawful purpose of collecting debts.
How you may access your personal information held by us and correct that information where it is incorrect
You are entitled to access the information we hold about you. Simple requests are best handled by speaking to the relevant Account Manager.
More complex requests may be better detailed in writing to ensure we fully understand and are able to respond accurately to your request. The Contact Us section of our website contains details of the ways you can contact us.
If there is a reason we are unable to agree to a request for access to your personal information, we will advise you of this in writing. Some examples of why we may refuse a request for access include where your request is frivolous or vexatious or, where providing the information:
· may pose a serious threat to the health or safety of an individual or the public;
· may have an unreasonable impact on the privacy of another individual;
· is not allowed by law; or
· may reveal internal information relating to a commercially sensitive decision-making process.
We aim to keep your personal information accurate and up to date. To assist us with this, you need to provide true, accurate, complete and current information to us. We may also check your personal information against public records to try and verify correctness or currency.
If information we hold about you is incorrect we would like to know so that we can promptly correct this. The Contact Us section of our website contains details of the ways you can contact us and request a correction.
In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request and you have the right to complain about the refusal in the manner set out in the next section.
How you may make a complaint about the way we collect, hold, use or disclose personal information and how we will deal with Privacy related complaints
If you want to make a complaint about our handling of personal information we ask that you contact us first. We will then follow our Internal Dispute Resolution (IDR) process and we will endeavour to respond within 20 days. If the matter proves to be more complex we will advise you of a revised response timeframe in writing.
The Contact Us section of our website contains details of the ways you can contact us to lodge a complaint.
For more detailed information on our complaint handling process please refer to our Complaints section.
ARL will undertake to notify our client of the complaint you have made as well and work towards impartially resolving your complaint. If you are not satisfied with the resolution provided by ARL and/or our client, you may refer the matter to the recognised External Dispute Resolution scheme (EDR) of which our client is a member.
Alternately you may refer your complaint to:
The Office of the Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601
Phone: 1300 363 992
Fax: 02 9284 9666
Who we may disclose personal information to:
In order ARL to provide our services to our clients we may also disclose personal information to businesses that provide services to us. We require all of these businesses to comply with strict confidentiality requirements and the APPs.
When we may disclose personal information to overseas recipients and the countries where such recipients may be located
ARL has dedicated staff employed through our US parent and based in the Philippines. All personal information is held and secured on technology located and maintained solely within Australia and we take measures to require that personal information that is accessed by these staff for the purposes of debt collection is treated in accordance with the standards that apply in Australia. In some circumstances the nature of our business may require us to disclose your personal information to an overseas credit provider, a representative acting on an individual’s behalf, other service providers and agents and credit reporting bureaus involved in the business interaction with ARL. It is not practical to list every country in which these recipients are located but any information will be disclosed in accordance with our obligations under Australian privacy law.
Tracking information on the web
For statistical purposes, we may collect information on website activity such as the number of users who visit our websites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that website. This information is obtained through the use of ‘cookies’ (refer below for more information about ‘cookies’).
Our website may also contain links to other sites. While these links are provided for convenience, if you are navigating these sites please be aware that the information handling practices of the linked websites may differ from ours. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other websites.
Whenever personal information is sent via our website we use high security levels to protect it. The security level of a web page can be viewed by clicking on the internet browser's padlock or key icon.
All personal information collected through this site and other sources will be kept private and held with the utmost care. ARL may use your IP (Internet Protocol) address to help diagnose problems with our server and to administer our website.
ARL will analyse website logs to improve the relevance of the content featured on the site. While ARL’s website logs are IP identifiable, no attempt is made to link them with any individuals that browse the site.
A ‘cookie’ is a packet of information that allows a website to identify and interact more effectively with a computer. Cookies do not identify you, but they do identify your browser type and Internet Service Provider.
Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. If cookies are rejected, there may be limits on how our websites can be used. To evaluate the effectiveness of our website, we may use third parties to collect statistical data. No personal data is collected on these occasions.
For more information, please see the help section on 'cookies' in your browser software.
Australian Receivables Limited (ARL) (ABN 03 234 653) is committed to complying with the Australian Privacy Principles (APPs). In accordance with those principles ARL will collect personal information from our clients, public sources of information, credit reporting bureaus and in some cases your personal information may be provided to us by third parties including someone authorised to act on your behalf, family members, friends, neighbours, colleagues, financial counsellors and legal representatives or field agents.
The personal information we collect includes your name, address contact details including phone and email, as well as some personal details such as date of birth, occupation, and certain financial information. In certain circumstances, we may also collect sensitive information about you such as health information but we will only collect sensitive information with your consent or where we are otherwise entitled to do so.
We collect personal information about you in order to perform our business functions and activities. The personal information collected is used to help us identify you when we are interacting with you. If you do not provide the necessary personal information we may not be able to achieve a satisfactory outcome in relation to your account.
We will take reasonable steps to let you know that we have your personal information, unless it is obvious from the circumstances that you would know or would expect us to have the information.
ARL may disclose your personal information to our clients, credit reporting bureaus, third parties acting on your behalf and to businesses that provide services to us, in order to perform our business functions and activities. If your personal information is disclosed to any business that provides services to us, ARL requires assurance that they comply with strict confidentiality requirements and the APPs.
This Policy is not a static document. We may make changes and update this Policy from time to time. The current Policy will always appear on our website.