At IMB, we believe that an individual’s right to keep their personal information private is very important. We are committed to protecting your right of privacy and ensuring the accuracy and security of all of your personal information in accordance with the Privacy Act (Cth) 1988, including the Australian Privacy Principles. We are also bound by Division 3 of Part IIIA of the Privacy Act and the Credit Reporting Privacy Code, which regulate the handling of credit related personal information by credit providers. These requirements do not apply to information about entities that are not individuals – for example companies or incorporated associations.
What personal information we collect
Personal information means information or an opinion about an individual who is identified, or who can reasonably be identified from that information. You may refuse to provide IMB with your personal information at any time. We may, however, be unable to provide you with certain products and services without certain personal details.
The kinds of personal information IMB collects include:
- Identifying information like your name, date of birth, gender, address and other contact details;
- Relationship information;
- Financial position;
- Account details and transactional and/or credit history;
- Place of employment;
- Identifiers assigned to you by the government such as your tax file number (TFN), Medicare card number, or Australian Business or Company Number (ABN or ACN);
- Complaint related information;
- Your reasons for applying for a product or service.
When you access our website, Internet Banking or Mobile Banking App, we may collect additional information about:
- IP address;
- contextual device information, such as application type and version, network type and carrier, security information or compromises;
- device specifications, such as device type and model, operating system and version; and
- 3rd party sites previously accessed.
Credit related personal information
Credit related personal information includes:
Credit information – the basic information that IMB collects about individuals who apply for credit. Credit information may be compiled by IMB and forwarded to credit reporting bodies such as Equifax, illion or Experian Australia in order to obtain a credit report about an individual (see the “Credit reporting bodies” section, below, for more information). Credit information may include:
- identity particulars (for example name, sex, date of birth, address and employment details);
- the fact that an individual has applied for credit and the amount;
- the fact that IMB is a current credit provider to an individual, which may include the date an account was opened, the type of credit provided, the maximum credit limit, repayment terms and the date an account was closed;
- details of payments which become overdue more than 60 days and for which collection action has commenced (and advice that such payments are no longer overdue);
- in specified circumstances, that in the opinion of IMB, an individual has committed a serious credit infringement;
- information about new credit arrangements an individual may have made with IMB, in relation to consumer credit currently or previously held, to deal with any defaults or serious credit infringements by that individual;
- that credit provided to an individual by IMB has been paid or otherwise discharged; and
- repayment history information.
Credit reporting information – includes any credit information held by a credit reporting body about an individual and any further information that the credit reporting body derives from that information that has a bearing on the individual’s credit worthiness and can be used to establish the individual’s eligibility for credit. When a credit reporting body provides credit reporting information at IMB’s request, it is referred to as a credit report. In addition to anything listed as credit information above, credit reporting information may also include:
- credit information provided to the credit reporting body by another credit provider;
- information about court judgments which relate to credit that an individual has obtained or applied for;
- information about an individual on the National Personal Insolvency Index;
- publicly available information about an individual’s credit worthiness; and / or
- an opinion, rating or other information provided by the credit reporting body in relation to an individual’s credit worthiness (for example a credit score).
Credit eligibility information – includes any credit reporting information received by IMB from a credit reporting body and any further information that IMB derives from that information that has a bearing on an individual’s credit worthiness and can be used to establish an individual’s eligibility for credit. This may include analysis and scoring that IMB conducts when assessing a loan application.
Sensitive personal information
The Privacy Act deems some personal information to be sensitive personal information. Sensitive personal information includes but is not limited to your medical history, religious views, ethnicity, sexual orientation, criminal record and political opinions.
We will not collect your sensitive personal information unless it is necessary to provide you with the product or service you request, for example it may be necessary for us or one of our alliance partners to request certain sensitive personal information to assess your application for certain types of insurance. You will be asked to consent to the collection and use of your sensitive personal information at the time we or one of our alliance partners collects it.
Anonymity and Pseudonymity
In most situations, we will require you to provide us with your personal information because we need this information in order to provide products and services to you. However, where it is lawful and practical to do so, we will provide you the option to deal with us anonymously or by using a pseudonym. For example, if you have a general inquiry about one of our products or services, you will generally not need to provide us with personal information.
Why we collect your personal information
IMB requires your personal information so that we can provide, manage and administer the products and services that you seek, efficiently and effectively. We collect your personal information:
- to provide you with information about a product or service;
- to assess any application for a product or service;
- to improve, personalise and manage the fraud monitoring of transactions conducted through online channels such as Internet Banking or the Mobile Banking App;
- to send you customer communications; and
- to communicate with you about IMB and our products and services.
As required by law
As a financial institution, IMB is required to collect certain information under various Australian laws and regulations. For example:
- the Anti-Money Laundering and Counter Terrorism Financing Act 2006 requires us to collect certain information, including to identify you, when we provide you with a product or service;
- the National Consumer Credit Protection Act 2009 requires us to, amongst other things, collect certain information from you which relates to your financial situation and needs (such as your objectives, income, assets and liabilities) when assessing your application for credit from us;
- due to the requirements of Australian tax legislation, IMB may need to ask you for information about your tax residency. If you are a US citizen or tax resident of a country other than Australia, IMB is required to collect details including your tax identification number (that is, foreign equivalent of an Australian Taxation Office tax file number) and provide those details to the Australian Tax Office. Those details may then be provided to other foreign jurisdictions for tax purposes.
How we collect your personal information
IMB will only collect your personal information by lawful and fair means. IMB will not ask you for personal information such as your account number or member number via e-mail, SMS or other non traceable means. Where it is reasonable and practical to do so, IMB will only collect personal information about you from you directly.
Generally we collect your personal information from you when you apply for one of our products or services or when you visit a branch or the IMB website, or we deal with you over the phone or internet. We will only ask you to provide the personal information that is relevant to your enquiry or the product or service you wish to acquire.
We may also collect information about you that is publicly available, including information from telephone directories, the electoral roll or other websites.
From a third party
Sometimes we may obtain your personal information from third parties, such as:
- our related entities, subsidiaries or joint venture companies, so that we can better manage and promote our relationship with you;
- alliance partners with whom IMB has an arrangement to jointly offer products or services or to share information for marketing purposes so that we may provide you with products or services and/or promote a product or service;
- alliance partners (such as insurance providers) from whom you have obtained a product or service, so that we can better manage our overall relationship with you, or from marketing companies to whom you have provided your personal information, so that we can tell you about our products and services;
- credit reporting bodies and other credit providers – to assess your credit worthiness, manage our credit relationship with you and, with your consent, obtain services such as credit pre-screening marketing services; and
- referees (including an employer), any broker, financial consultant, accountant, lawyer, or any other adviser acting for you.
Where it is necessary to obtain personal information about you from other sources (for example your credit reporting information from a credit reporting body), we will seek your consent and tell you from whom or where we are collecting the information and why.
How we store and secure your personal information
We are committed to protecting your personal information (including credit related personal information) from loss and unauthorised access, use, modification and disclosure.
IMB maintains physical security at all our locations. Only our staff and service providers who are authorised to handle your information will have access to your personal information.
We may store your personal information in hard copy documents or electronically. IMB has document handling procedures in place, including secure offsite storage facilities, to ensure your information is protected from misuse, loss and unauthorised or illegal access or use.
Your personal information is protected where we store your information electronically or when you deal with us over the phone or internet, including through our internet banking site. We have computer and network security including firewalls and other security devices to protect your information. You are required to maintain the security of your access codes (such as your PIN number or Internet Banking access code) at all times. You must tell us immediately if you believe your access codes are no longer private to you.
Once IMB no longer requires your personal information for any purpose we will take reasonable steps to destroy or permanently de-identify that information.
For more information about our commitment to securing your personal information, please visit the IMB and Your Security section of our website at http://www.imb. com.au/personal-member-space-your-security.html.
How we use your personal information
IMB will only use your personal information for the purpose for which it was collected. Generally we use your personal information for the following purposes:
- to provide you with information about a product or service;
- to identify you and, in some cases, establish your taxation status under Australian and/or foreign laws;
- to obtain further details about you, such as from a credit reporting body. You will be asked to consent to such uses at the time you disclose the relevant information to us;
- to assess any application for a product or service;
- to provide, manage and administer the products and services you seek
- to communicate with you about us and our products and services, including to market our, or our alliance partners’ products and services to you. You will be given the option to opt out of receiving such communications;
- to improve, personalise and manage the fraud monitoring of transactions conducted through online channels such as Internet Banking or the Mobile Banking App;
- as required under various Australian laws and regulations including the Anti-Money Laundering and Counter Terrorism Financing Act 2006 and the National Consumer Credit Protection Act 2009.
We will not use your information for any other purpose unless you consent or you would reasonably expect IMB to use the information for that purpose, or we are required or authorised to do so by law.
IMB may use your personal information, including your contact details, to provide you with information about our products and services, or our alliance partners products and services that we think might be of interest to you. This may include disclosure of your personal information to credit reporting bodies for the purposes of credit pre-screening. Credit pre-screening is a service provided by credit reporting bodies which uses information held by the credit reporting body to screen out individuals who do not meet criteria set by IMB when we wish to send direct marketing material about our credit services.
We will consider that you consent to the use of your personal information in this way unless you opt out. You may opt out if you no longer wish to receive marketing information or do not wish to receive marketing information through a particular channel, such as email. You can opt out of these communications at any time by calling 133-462 or visiting an IMB Branch. You can also unsubscribe from email and SMS communications by visiting www.imb.com.au/unsubscribe.
You may also request that a credit reporting body not use your credit related personal information for marketing purposes (see the “Credit reporting bodies” section, below, for further information).
IMB is able to contact our members who are registered on the Do Not Call Register. As a member of IMB, we will need to contact you on occasion in relation to the products and services you have with us. IMB will not, however, contact you with offers of other products and services that we think may be of interest to you if you have opted out of receiving these communications from us.
We do not use your information acquired through using the Mobile Banking App for serving advertising.
To whom we disclose your personal information
In the course of our relationship with you it may be necessary for IMB to disclose your personal information to other parties. We may disclose your personal information to:
- a related entity, subsidiary or joint venture company;
- our alliance partners such as insurers, credit card and other financial service providers;
- organisations who perform services on our behalf including but not limited to mailing services, payment system operators and processing services, document storage services, data verification services, information technology support services including for the purpose of systems and product development, real estate agents, property valuers, market research entities, rating agencies, debt collection services (if you do not make repayments in accordance with your credit contract), insurers and reinsurers (including mortgage insurers), organisations involved in what are called securitisation arrangements, organisations that assist in the identification, investigation and prevention of fraud or unlawful activity and professional advisers including accountants, lawyers and auditors;
- government and regulatory authorities (including state and territory credit assistance schemes and external dispute resolution schemes) if required or authorised by law;
- credit reporting bodies; and / or
- other credit providers and their professional advisors.
IMB may also be required to disclose personal information in response to a court order or subpoena or other legally binding document.
Further, when you instruct people to act on your behalf such as brokers, superannuation fund representatives, financial advisers, attorneys, lawyers and accountants, or you appoint someone else to act on your behalf, IMB assumes that you consent to the disclosure of your personal information to those people.
IMB is also required or authorised to disclose certain information under various laws to government agencies such as the Australian Taxation Office (ATO), the Australian Prudential Regulation Authority (APRA), Australian Securities and Investment Commission (ASIC), state and territory credit assistance schemes and the Australian Transactions Reports and Analysis Centre (AUSTRAC). The information provided to the ATO may also be provided to other foreign jurisdictions for tax purposes. In certain circumstances, IMB is also permitted to disclose your personal information (including credit related personal information) to external dispute resolution scheme providers such as the Australian Financial Complaints Authority and the Office of the Australian Information Commissioner (see the “What to do if you think your privacy has been interfered with” section, below, for further information on external dispute resolution).
When you apply for credit, IMB may disclose credit related personal information to any referees (including an employer) that you list on the application as well as any joint borrower(s) or account holder(s) or a proposed guarantor(s).
Further, IMB may disclose your credit related personal information to credit reporting bodies, other credit providers and their professional advisors.
Credit reporting bodies
A credit reporting body may provide us with credit related personal information about you that we use to help assess your credit worthiness. If you do not meet your repayment obligations under a credit contract or we reasonably believe you have committed a serious credit infringement, we may be entitled to disclose the details to credit reporting bodies.
IMB may use credit reporting information obtained from credit reporting bodies (as well as other credit related personal information supplied by you or by another credit provider) to:
- to assess an application for credit (or an application to guarantee another person’s credit contract);
- in certain circumstances, to conduct reviews of your IMB loans;
- to collect overdue payments from you;
- in certain circumstances, to notify credit reporting bodies, a debt collection service and / or other credit providers of a default by you;
- in certain circumstances, to notify credit reporting bodies that, in our opinion, you have committed a serious credit infringement;
- for marketing purposes, including but not limited to credit pre-screening purposes;
- to exchange information with other credit providers as to the status of your IMB loan(s) where you are in default with any other credit provider;
- to assess your credit worthiness; and / or
- for any other lawful purpose.
If you believe, on reasonable grounds, that you have been, or are likely to be, the victim of a fraud (including identity theft), you have the right to request that a credit reporting body not provide your credit related personal information to credit providers such as IMB for a period of 21 days. This is known as a ban period. You may also request that a credit reporting body not use your credit related personal information for marketing purposes.
IMB may disclose credit information to the credit reporting bodies listed below, each of which maintains a policy that explains how it manages your credit related personal information. You can request copies of these policies and further information on how these credit reporting bodies deal with personal information by contacting them directly using the details below.
|illion Australia and New Zealand Pty Ltd||Experian Australia Credit Services Pty Ltd||Equifax Australia Information Services and Solutions Limited|
Phone: 1300 734 806
Mail: 479 St Kilda Rd,
Melbourne Victoria 3004
Phone: 1300 784 134
Mail: Experian Australia Credit Services Pty Ltd PO Box 1969
North Sydney NSW 2060
Phone: 1300 850 211
Mail: Equifax Australia Information Services & Solutions Ltd
PO Box 964
North Sydney NSW 2059
Refusal of credit applications
We may refuse an application for consumer credit made by you individually or with other applicants. Our refusal may be based on credit reporting information obtained from a credit reporting body about you, another applicant or a proposed guarantor. In such cases, we will give you written notice that the application has been refused on the basis of that information. We will tell you the name and contact details of the relevant credit reporting body and other relevant information.
Some of our service providers, for example technology and operational service providers, may be located overseas or have operations overseas. We may disclose your personal information, including credit related personal information, to these service providers where it is necessary for the provision of those services. Where we do disclose your information overseas, the Privacy Act requires us to take measures to ensure your information is treated in accordance with the Australian Privacy Principles.
The nature of the product or service you request may also require us to disclose your personal information overseas, for example if you ask us to transfer funds to an institution or organisation located overseas we will be required to disclose information necessary to action your request.
The countries where we are likely to disclose your personal information include, but are not limited to, the USA, UK, India, the Philippines and countries in the EU.
Access & Correction
You can request access to, and correction of, the personal information (including credit related personal information) we hold about you. You do not need to give a reason for seeking access to your personal information but we may require you to demonstrate to us why a correction to your personal information is required.
We will give you access to that information unless legislation allows us or requires us to refuse access, in which case we will provide you with reasons as to why we have declined your request for access.
In the case of personal information that is not credit related personal information, this may happen where:
- access would pose a serious threat to the life or health of any individual;
- access would have an unreasonable impact on the privacy of others;
- the request is frivolous or vexatious;
- the information relates to a commercially sensitive decision making process;
- access would be unlawful;
- access would prejudice enforcement activities relating to criminal activities and other breaches of law; and/or
- legal dispute resolution proceedings are on foot.
In the case of credit related personal information, this may happen where:
- providing access would be unlawful;
- providing access would be likely to prejudice an enforcement related activity; and / or
- where IMB is required or authorised by or under an Australian law or order of a court or tribunal to decline to provide access.
We will not charge a fee for requesting access to your personal information or for making a correction to your personal information. We may charge a fee for giving you access to your personal information. Before we act on your request, we will tell you how much this service is expected to cost. We will endeavour to deal with your requests in relation to personal information within a reasonable timeframe. In the case of credit related personal information, if we are unable to deal with your request within 30 days of receiving it, we will write to you to request more time to do so.
We take reasonable steps to ensure that your personal information (including your credit related personal information) is accurate, complete and up-to-date. If you think that any personal information we hold about you is incorrect, you may ask us to correct it and we will take reasonable steps to do so, unless we disagree with your reasons. If we decline to correct your personal information we will give you an explanation as to why.
Your identity will be confirmed (including by verifying your signature) before we process your access or correction requests. Requests for access or correction to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled in a branch or over the telephone. In some cases, you will be requested to fill out a “Request for Access or Correction Form” and specifically identify the information you wish to access or correct.
If IMB holds credit related personal information about you, you can also request that IMB assist you to correct credit related personal information that is held by a third party. IMB will take reasonable steps to support such a request and provide you with a response within 30 days of your request.
If you make a request to correct credit related personal information held by IMB and IMB agrees to make the correction, you may also request that IMB provide notice of the correction to third parties to whom IMB has previously disclosed the pre-corrected information.
You can request access to, or the correction of, your personal information by visiting one of our Branches, calling us on 133 462, via www.imb.com.au (using our online enquiry form or via secure email in Internet Banking) or by writing to IMB’s Privacy Officer at PO Box 2077 Wollongong, NSW 2500.
What to do if you think your privacy has been interfered with
If you have a question or a concern in relation to IMB’s collection, use or disclosure of your personal information (including credit related information), or you believe IMB has breached its obligations under the Privacy Act or the Credit Reporting Privacy Code, please contact us and we will endeavour to resolve your concern.
If you are dissatisfied with the initial response, you can make a complaint in accordance with IMB’s Internal Dispute Resolution Policy, details of which can be obtained by visiting one of our Branches, calling IMB or writing to or emailing us.
Once a privacy related complaint has been lodged, IMB will acknowledge your complaint within 7 days and will aim to resolve your complaint within 30 days. We will aim to deal with your complaint at the source of the complaint. If you are not satisfied with the response you receive, please let us know. If we can’t resolve your complaint face-to-face or over the phone, we encourage you to direct your complaint in writing to:
Member Relations IMB Ltd PO Box 2077 Wollongong NSW 2500
If you are still not satisfied, you can contact external bodies that deal with privacy complaints – the Australian Financial Complaints Authority (which is our external dispute resolution scheme) or the Office of the Australian Information Commissioner (which oversees privacy laws in Australia). These services are free of charge. Either of these bodies may forward your complaint to another external dispute resolution body if it considers the complaint would be better handled by that other body.
Contact details for these external dispute resolution services providers are as follows:
|Office of the Australian Information Commissioner||Australian Financial Complaints Authority (AFCA)|
GPO Box 5218 Sydney NSW 2000
Ph: 1300 363 992
GPO Box 3 Melbourne VIC 3001 (Australia) Ph: 1800 931 678
Fax: (03) 9613 6399
Where can you get further information?
- speak to our staff in any IMB Branch
- call us on 133 IMB (133 462)
- Online: at www.imb.com.au, using our online enquiry form
- Write to us at: Privacy Officer, PO Box 2077, Wollongong NSW 2500