‘We’, ‘us’ and ‘our’ refers to;
- Castle Compensation Partners
OUR COMMITMENT TO PROTECT YOUR PRIVACY
We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 1988 (Cth) and any other relevant law.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.
Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history, defaults, personal insolvency information and court proceeding information. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.
The kinds of personal information we may collect about you include your name, date of birth, address, account details, why you are applying for a particular product, details of superannuation policies, details about your motor vehicles, occupation, details about your assets and liabilities and any other information we made need to identify you.
If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of your earnings and expenses. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.
We may also collect sensitive information about you. We will only collect sensitive information from you. Sensitive information may include information about your health, ethnic origin, or criminal records.
WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information for the following purposes:
- arranging an application for finance or other product;
- assessing your application for finance and managing that finance or other product;
- assessing your financial situation and discharging our duties and functions under the Bankruptcy Act 1966 (Cth); the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and the National Consumer Credit Protection Act 2009 (Cth);
- providing debtor finance, invoice discounting or other service you have requested; or
- providing services in relation to debt administration, debt agreements, bankruptcy and personal solvency agreements;
- direct marketing; and
- managing our relationship with you.
From time to time we may offer you other products and services. To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. The types of organisations to which we are likely to disclose information about you to include other mortgage intermediaries, lenders, valuers, lenders mortgage insurers, surveyors, accountants, credit reporting bodies, recoveries firms, debt collectors and lawyers. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your finance, or in our business.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Where reasonable and practical, we will collect your personal information directly from you. We may also collect your personal information from reporting bodies and other government agencies including or as provided for under Australian law.
DO WE DISCLOSE YOUR PERSONAL INFORMATION?
We may disclose your personal information:
- to prospective lawyers or other intermediaries in relation to your compensation requirements;
- to other organisations that are involved in managing or administering your compensation such as third party suppliers, printing and postal services, call centres, trade insurers and credit reporting bodies;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us;
- to anybody who represents you, such as finance brokers, lawyers, and accountants;
- to anyone, where you have provided us consent;
- where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth); or
- to investors, agents or advisers, or any entity that has an interest in our business;
- to external dispute resolution schemes, courts and tribunals;
- to government agencies including the Australian Law Authority, State Trustees, Centrelink or child support agencies; or
- to your employer, referees or identity verification services; or
- any one that you provide your consent for us to disclose your personal information to, such as your creditors.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment,
(b) you have consented to us making the disclosure; or
(c) we are required to make the disclosure under Australian law.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.
We may disclose your personal information to overseas entities that provide support functions to us, including India. You may obtain more information about these entities by contacting us.
We do not disclose your credit information overseas.
If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a credit reporting body.
You have the right to request access to the personal information that we hold about you and make a request for us to correct that personal information if needed. Please see the heading “Access and correction to your personal information”, below.
From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If you do not wish to receive marketing information, you may at any time decline to receive such information by email email@example.com
UPDATING YOUR PERSONAL INFORMATION
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you, we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
ACCESS AND CORRECTION TO YOUR PERSONAL AND CREDIT INFORMATION
We will provide you with access to the personal and case information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal or credit information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you, if we deny you access to the personal or case information we hold about you.
If any of the personal or case information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit information within 30 days.
We may need to consult with other law providers or reporting bodies or entities as part of our investigation.
If we refuse to correct personal or credit information we will provide you with our reasons for not correcting the information.
USING GOVERNMENT IDENTIFIERS
If we collect government identifiers, such as your tax file number, Centrelink customer reference number, passport number or driver’s license details, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
BUSINESS WITHOUT IDENTIFYING YOU
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
HOW SAFE AND SECURE IS YOUR PERSONAL INFORMATION THAT WE HOLD?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our complaints officer via recorded email firstname.lastname@example.org clearly stating that you wish to make an official complaint.
We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 45 days.
If you are dissatisfied with the response of our complaints officer you may make a complaint to our External Dispute Resolution Scheme, Credit Ombudsman Service Limited which can be contacted on 1800 138 422, www.cosl.com.au or PO Box A252, Sydney South NSW 1235 or the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992 or the Australian Financial Security Authority on 1300 364 785 or www.afsa.gov.au/
You may request further information about the way we manage your personal or credit information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.