COLLECTION OF INFORMATION
What kind of information is collected?
In the course of conducting business, SOS Charge will only collect and retain personal information that you provide that is reasonably necessary for, or directly related to, one or more of our functions or activities or is permitted by law. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.
The kinds of personal information SOS Charge collects include, but are not limited to:
- Names, addresses, email addresses, phone numbers, business details and other contact details of members and their staff;
- Contact information;
- Other information relevant to customer surveys and/or offers;
- Photos and identification documents;
- Credit card and other payment/ bank details;
- Information about an individual’s employment, occupation and services rendered;
- Information in relation to an individual’s studies and/or training history;
- Records of contact with the individual.
SOS Charge will only collect and hold sensitive information (information about an individual’s race, ethnic origins, political opinions, membership of trade unions, criminal records and health information etc) if the individual consents to such collection and if it is reasonable necessary for, or directly related to, one or more of SOS Charge’s contracts or where it is required by law. For example, SOS Charge may require information about ethnic origins or preferred languages for training purposes.
SOS Charge may also collect the following kinds of Credit Information if you ask us to or we afford you credit or when we are acting as or as an agent of a credit provider:
- Details of consumer credit or commercial credit (including the name of each relevant credit provider) that you have applied for, the type and amount of that credit and the fact that a credit provider, mortgage insurer or trade insurer has sought information about you from a credit reporting body in relation to an application;
- Consumer credit liability information, being details of consumer credit that you have or had including the credit provider, the type of consumer credit, the day on which it was entered into, terms or conditions that relate to the repayment of the amount of consumer credit, the maximum amount of credit available and the day on which the consumer credit is terminated or otherwise ceases;
- Repayment history information, which includes whether in relation to your consumer credit facilities you have made payments when due and, if not, when overdue payments have been made;
- Default information;
- Tax file number;
- Salary details;
- Payment information, which includes details of the date on which you have paid overdue amounts that were previously recorded as default information with a credit reporting body;
- Whether in our or another credit provider’s opinion you have committed a serious credit infringement;
- Court proceedings information, which includes information about a judgement against you in proceedings that relate to any credit that has been provided to, or applied for, by you;
- Personal insolvency information;
- Certain publicly available information;
- Scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us or by credit reporting bodies wholly or partly on the basis of the information above;
- Certain administrative information relating to credit, such as account and customer numbers.
How we collect information
SOS Charge only collects information by lawful and fair means. Generally, personal and sensitive information will be collected from the individual or their authorised representatives. Personal information may also be collected from third parties to whom SOS Charge or the individual engages to provide services to the individual or SOS Charge in relation to our business relationship with the individual.
SOS Charge may collect personal information by third parties not mentioned above, or publicly available sources but only in the event that it is impracticable to obtain the personal information from the individual.
Examples of how SOS Charge may collect personal information include, but are not limited to:
- Events and training, including enrolment forms;
- Phone contact with customers to clarify and update information on database;
- Research in relation to policy issues;
- Employment queries and applications;
- General engagement with individuals in the course of conducting our business.
Examples of how SOS Charge may collect Credit Information include, but are not limited to:
- From the Application For Credit documentation completed by you;
- From credit reporting bodies;
- From credit providers.
Unsolicited personal information
If SOS Charge obtains personal information without requesting the personal information (‘unsolicited personal information’) and the personal information could not have been lawfully collected under the APPs, the personal information will be destroyed or de-identified if it is lawful and reasonable to do so.
Notification of collection of personal information
Subject to the APPs, if SOS Charge acquires any personal information from a third party as mentioned above, we will only hold that personal information if it is reasonably necessary for, or directly related to, a function of SOS Charge.
As soon as reasonably practicable after obtaining information from a third party, or obtaining unsolicited personal information about an individual, we will notify the individual about the nature of the personal information obtained, the purposes of collection, the use and disclosure of that information and information about this policy and our policy procedures.
Purpose of collection
SOS Charge collects personal information to enable it to provide services to the individual and the individual’s business, and to fulfill other legal obligations. Such services include:
- Supplying, marketing or acquiring products and services; responding to individuals’ enquiries and feedback; providing information about our new products, specials and services that may be of interest to individuals; maintaining a relationship with individuals;
- Market research, surveys, and product and service development, so that we are able to better understand our customers’ needs and tailor our future products and services accordingly;
- Performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
- Employment-related purposes, such as recruiting and providing services to staff; and
- Other purposes related to or in connection with our business, including meeting our legal and contractual obligations to third parties and for internal corporate governance purposes.
SOS Charge collects Credit Information:
- To consider whether to provide you, or an entity associated with you, with credit;
- To consider whether to accept you as a guarantor; and
- Internal management purposes directly related to considering an application or credit or whether you should be accepted as a guarantor.
USE AND DISCLOSURE OF INFORMATION
SOS Charge will only use your personal information for the purposes it was collected (as mentioned above), or related purposes, and only where the personal information is relevant to the use. Personal information may be disclosed to internal staff of SOS Charge, and other third parties engaged by the individual or SOS Charge to provide services to the individual or SOS Charge in relation to our business relationship with the individual. Third parties may include:
- Parties engaged by us to provide products or services. For example, processing payment information, managing databases, marketing, training and advertising;
- External advisers. For example where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct;
- Members of the public, such as when referring work; and
- Other parties or for other purposes as agreed to by the person, or as required or permitted by law.
Personal information will not be used for purposes other than those described above (and related to those above) unless you have consented to that use or it is permitted by law.
SOS Charge will not use or disclose an individual’s sensitive information unless it is reasonably necessary for, or related to, one or more functions of SOS Charge and the individual has consented to it.
With respect to Credit Information, you should be aware that:
- We may collect information about you and refer it to a credit reporting body where the Act permits us to do so;
- The credit reporting body may include the information in reports provided to credit providers to assist them to assess your individual credit worthiness;
- If you fail to meet your payment obligations in relation to consumer credit or you commit a serious credit infringement, we can disclose this to a credit reporting body;
- You can obtain a copy of the credit reporting bodies’ policy about the management of credit related personal information at the following websites:
- You have the right to access your information, correct and it and make a complaint (the processes for this are detailed later in this policy);
- You have a right to request a credit reporting body not to use their credit reporting information for the purposes of pre-screening of direct marketing by us; and
- You have the right to request a credit reporting body not to use or disclose credit reporting information about you if you believe on reasonable grounds that you have been or a likely to be a victim of fraud.
The above points are called ‘notifiable matters’ and are provided in accordance with the CR Code.
Direct Marketing use and disclosure
SOS Charge may use and disclose individuals’ personal information to provide individuals with information about our products and services that we consider may be of interest to the individual. An individual may contact us during business hours (see ‘how to contact us’) if they wish to opt out of receiving further marketing communications and offers. All direct marketing communications will provide an opportunity to opt out from receiving further communications of this nature. No sensitive information will be used for direct marketing purposes.
QUALITY OF INFORMATION
SOS Charge will take reasonable steps to ensure that the information we collect, hold, use and disclose is accurate, complete and up-to-date. SOS Charge relies on individuals to advise us of any changes or corrections to the information we hold about the individual. An individual is able to contact us (see ‘how to contact us’) and ask for the correction of personal information we hold if the individual believes the information we hold is inaccurate or incomplete.
SECURITY OF PERSONAL INFORMATION
SOS Charge takes reasonable steps to keep personal information protected from loss, misuse and unauthorised access, modification and disclosure. We use a variety of physical and electronic security measures including restricting physical access to our offices, firewalls, appropriate encryption and secure databases.
When personal information that we collect is no longer required, we will take reasonable steps to destroy or permanently de-identify the personal information.
ACCESS TO INFORMATION
An individual may contact us (see ‘how to contact us’) to access the personal information that we hold about the individual. We will respond to such a request within a reasonable period after the request is made. There are occasions where this access may be denied under the exemptions contained in the Privacy Act. If we deny access in some circumstances, we will advise the individual why we have denied such a request. No fee applies for requesting access to information we hold about individuals. However, we reserve the right to charge a reasonable fee where we do provide access.
CORRECTION OF INFORMATION
An individual may also contact us (see ‘how to contact us’) to correct the personal information that we hold. We will deal with your request within a reasonable period after the request is made. We will take all reasonable steps to correct that information and ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
In respect of Credit Information, if we consider it necessary in order to deal with your request, we may consult with a credit reporting body or another credit provider.
An individual’s continued use of our website, products or services, requesting our assistance, or the provision of further personal information to us after this policy has been revised, constitutes the individual’s acceptance of the revised policy.
MAKING A COMPLAINT
If your complaint is in respect of your Credit Information, then the following applies:
- You will receive an acknowledgment of your complaint within 7 days after we receive it;
- We will investigate all complaints and aim to resolve them within 30 days;
- If we cannot resolve your complaint within this period we will notify you as to the reasons why, specify a date when we expect a resolution and seek your agreement to extend this 30 day period;
- If we consider it necessary in order to deal with your complaint, we may consult with a credit reporting body or another credit provider. If, while the complaint remains unresolved, we are disclosing information subject to the complaint to a third party, we may advise the third party about the complaint;
- You may also complain to the Privacy Commissioner;
- Depending on the nature of the complaint, sometimes we will be required to notify a credit reporting body or credit provider of the making of the complaint and our decision.
HOW TO CONTACT US
For further information contact us during business hours at:
The Privacy Officer
PO Box 551
Glenelg, SA 5045