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PCA Advisory

Privacy and Credit Reporting Policy

1. Your rights in relation to privacy

PCA Advisory understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how PCA Advisory aims to protect the privacy of your personal information, your rights in relation to your personal information managed by PCA Advisory and the way PCA Advisory collects, holds, uses and discloses your personal information.

In handling your personal information, PCA Advisory will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. To the extent PCA Advisory handles your credit information, PCA Advisory will also comply with the Credit Reporting Code. This policy may be updated from time to time.

2. What kinds of personal information does PCA Advisory collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and/or services, PCA Advisory may collect your personal information.

Generally, the kinds of personal information PCA Advisory collects are:

(a) contact and identification information such as your name, address, telephone number and email address;
(b) information relating to your interests;
(c) where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
(d) financial information about your assets, occupation and income, account balances, account activities, payment history and transactions with us or third parties;
(e) details of directorships, shareholdings or other investments you hold;
(f) credit information, being credit related personal information lawfully created and accessible within the Australian credit reporting system, including:

  1. identification information;

  2. whether you have or have not met any repayment obligations;

  3. whether you have defaulted on a payment (ie. a payment that is at least 60 days overdue and over $150 in value) provided PCA Advisory has notified you in accordance with the Privacy Act;

  4. whether you have paid any amount previously reported as being in default;

  5. that another credit provider has sought credit-related personal information about you from a credit reporting body;

  6. information about the types of consumer or commercial credit, and the amounts of credit, you have sought from a credit provider;

  7. information about court proceedings related to credit provided to you or for which you have applied;

  8. personal insolvency information and other publicly available information relating to your credit worthiness;

  9. a credit provider’s reasonable belief that you have committed a serious credit infringement; and

  10. any other information lawfully obtainable within the Australian credit reporting system;

(g) credit eligibility information which is credit-related information about you that PCA Advisory obtains from a credit reporting body such as Equifax Pty Ltd (Equifax) and Dun and Bradstreet (DNB) (the details of which are set out in paragraph 5), together with information PCA Advisory derives from such information based on its own analysis including internally generated scores, ratings and other assessments used to evaluate your credit worthiness; and

(h) sensitive information including health information and criminal record information where you are applying for a position with PCA Advisory and it is relevant to the recruitment process through which you must progress.

In some circumstances PCA Advisory may also hold other personal information provided by you.

3. How does PCA Advisory collect personal information?

Generally, PCA Advisory collects your personal information directly from you, through the completion of a manual or online form, an interaction or exchange in person or by way of telephone, facsimile, email, post or through the use of the PCA Advisory website. There may be occasions when PCA Advisory collects your personal information from other sources such as from:

(a) an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for PCA Advisory to provide its products and/or services to that entity through you;
(b) the completion of an application form by another person or entity that lists you as a director, guarantor, potential guarantor or trade reference;
(c) Equifax, DNB or other credit reporting body;
(d) other credit providers;
(e) an information services provider;
(f) a publicly maintained record or other publicly available sources of information including social media and similar websites;
(g) PCA Advisory’s own records about you, from which PCA Advisory may internally generate its own scores, assessments or deductions, particularly in relation to your credit worthiness;
(h) if for recruitment purposes, an external recruitment or background screening services provider or a health service provider to obtain, where necessary and relevant, health information; or
(i) a government agency.

Generally, PCA Advisory will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

PCA Advisory may also collect information about the way you use our website including through the use of ‘cookies’. Cookies are small files that assist us to identify website user preferences so that we can enhance and tailor your experience of our website. Sometimes cookies result in the collection of personal information. You may disable the use of cookies through your internet browser.

4. Why does PCA Advisory need your personal information?

PCA Advisory collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:

(a) providing to you our products and/or services;
(b) responding to your requests;
(c) providing you with further information about PCA Advisory;
(d) identifying and informing you of products, services and events of PCA Advisory or selected third parties that may be of interest you;
(e) assessing an application for, and if successful, administering, a consumer or commercial credit account with PCA Advisory (including assessing your application to act as a guarantor in relation to the credit);
(f) accounting, billing and other internal administrative purposes;
(g) assessing your application for employment with PCA Advisory or otherwise for the purpose of engaging you as a contractor or consultant; and/or
(h) any other legal requirements.

PCA Advisory may also use your personal information for purposes related to the above purposes and for which you would reasonably expect PCA Advisory to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.

Where personal information is used or disclosed, PCA Advisory takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to PCA Advisory. However, without certain information from you, PCA Advisory may not be able to provide its products and/or services to you.

5. To whom does PCA Advisory disclose your personal information?

PCA Advisory discloses your personal information for the purpose for which PCA Advisory collects it. That is, generally, PCA Advisory will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:

(a) third parties engaged to perform administrative or other business management functions, including debtor management;
(b) people or entities considering acquiring an interest in PCA Advisory’s enterprise or assets;
(c) PCA Advisory’s professional advisors, contractors, consultants and related bodies corporate;
(d) mailing houses;
(e) debt collectors and credit management agencies;
(f) third parties who act as guarantors in relation to credit we provide to you;
(g) insurance providers; and
(h) regulatory bodies if and as necessary.

PCA Advisory may also disclose your personal information, including your credit information, to lenders, other credit providers and the credit reporting bodies, Equifax and DNB (contactable on the details set out below). In particular, PCA Advisory may disclose to Equifax or DNB information about you failing to meet your payment obligations or if you commit a serious credit infringement. Equifax or DNB may include any information provided to it by PCA Advisory in reports that it provides to other credit providers for the purpose of such credit providers assessing your credit worthiness.

PCA Advisory’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. PCA Advisory may also disclose your personal information with your consent or if disclosure is required or authorised by law.

6. Overseas disclosure

PCA Advisory may disclose personal information to overseas recipients in order to provide our products and/or services. PCA Advisory may also store, process or back-up your personal information on computer servers or networks which are located overseas or in the cloud, including where services are performed by service providers who are located overseas. PCA Advisory does not disclose any credit information to any recipient located outside of Australia.

It is not practicable to list all countries in which recipients may be located, however, PCA Advisory will only disclose your personal information to an overseas recipient where reasonably necessary in order to provide its products and/or services and for administrative, data storage or other business management purposes.

Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, PCA Advisory will take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.

7. Direct marketing

PCA Advisory may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt out by contacting PCA Advisory via the contact details set out in paragraph 11 or through any opt out mechanism contained in a marketing communication to you. PCA Advisory will not use or disclose credit-related personal information for direct marketing purposes.

8. Security of your personal information

PCA Advisory takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. PCA Advisory holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.

PCA Advisory will destroy or de-identify personal information in circumstances where it is no longer required, unless PCA Advisory is otherwise required or authorised by law to retain the information.

9. Access and correction

PCA Advisory takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by PCA Advisory.

PCA Advisory will endeavour to respond to your request within 30 days. If PCA Advisory refuses your request, PCA Advisory will provide written reasons and details of complaint mechanisms.

10. Privacy complaints

Please direct all privacy complaints to the Accountant who manages your relationship with PCA Advisory.

Complaints:

(a) will be treated seriously;
(b) will be dealt with promptly;
(c) will be dealt with in a confidential manner; and
(d) will not affect your existing obligations or commercial arrangements.

You may refer unresolved complaints to the Office of the Australian Information Commissioner.

11. How to contact us

For further information or enquiries regarding your personal information, please contact the Accountant who manages your relationship with PCA Advisory.