The privacy of customer information is of paramount importance to Cuscal and our aim is to provide you with the best possible service, while protecting your privacy and ensuring that your information is secure.
Cuscal is committed to safeguarding personal information it may collect or hold at any time in respect of any individual and is committed to doing so in accordance with the requirements of the Privacy Act 1988 (Cth).
Personal information that we hold will be held in accordance with the Australian Privacy Principles (“APPS”) and Cuscal will:
- take reasonable steps to ensure that the information, if used, is accurate, complete and up-to-date;
- take reasonable steps to protect the information from misuse, loss or unauthorised access or disclosure;
- provide you with access to the information if we still use it;
- not use any government identifier to identify you; and
- only transfer such information overseas with your consent or as otherwise authorised.
Collection of personal information
Ordinarily we will only collect information about you when you provide it to us or it is provided to us with your authority.
In certain circumstances, we may also collect sensitive information. Sensitive information includes information about your health, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection. If the sensitive information relates directly to your ability to meet a financial obligation to us, you consent to its collection.
We will collect personal information directly from you when you complete an application form for one of our products or services, deal with us over the telephone or in person, send us a letter or visit our website.
On occasions, we may need to collect personal information about you from third parties, such as credit reporting agencies, our business alliance partners, your financial institution, or your agents. If required by law, we will obtain your consent to collect information from third party sources.
As a general rule the collection of your information will be necessary for us to provide a service to you or to maintain our relationship with you.
Additionally, the purposes for which we will generally collect and use your personal information will include:
- complying with legislative and regulatory requirements;
- considering any application you make to us;
- performing our administrative operations, including accounting, risk management, record keeping, archiving, systems development and testing, and staff training;
- managing our rights and obligations in relation to external payment systems;
- conducting market or customer satisfaction research;
- developing, establishing and administering alliances and other arrangements (including rewards programs) with other organisations in relation to the promotion, administration and use of our respective products and services;
- developing and identifying products and services that may interest you; and
- (unless you ask us not to) telling you about products and services.
If at any time you supply us with personal information about another person (for example, a referee) you should ensure that you are authorised to do so and you must agree to inform that person who we are, that we will use and disclose their personal information and that they may gain access to it should we hold that information.
Use and disclosure of personal information
You authorise Cuscal to disclose necessary information to related companies and to any agents or contractors who provide services to us in connection with the provision of products or services you have sought from us. These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.
Subject to what is permitted by law, the types of third parties we may disclose your personal information to include:
- financial institutions that provide credit to Cuscal customers;
- credit reporting agencies;
- our agents, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions and activities;
- your referees, including your employer;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- any person or organisation who introduces you to us;
- other organisations with whom we have alliances or arrangements (including rewards programs) for the purpose of promoting our respective products and services (and any agents used by us and our business partners in administering such an arrangement or alliance);
- anyone supplying goods or services to you in connection with a rewards program associated with a facility we provide to you;
- debt collecting agencies;
- other financial institutions, including your credit union;
- external payment systems operators;
- your and our insurers or prospective insurers and their underwriters;
- your guarantors and prospective guarantors;
- an organisation proposing to fund the acquisition of, or acquire any interest in any obligation you may owe us, that organisation’s agents, persons involved in assessing the risks and funding of the acquisition and, after acquisition, the purchaser and any manager.
- any person to the extent necessary, in our view, in order to carry out any instruction you give to us;
- (unless you tell us not to) other organisations (including our related bodies corporate) for the marketing of their products and services.
In some cases, we may need to transfer your personal information outside Australia. Countries where our suppliers might hold personal information overseas currently include the United States of America, United Kingdom, Italy and India.
Your access to your personal information
If at any time you wish to know what personal information we hold about you, you may request your details by writing to the Privacy Officer, Cuscal Limited at GPO Box 4720 Sydney NSW 2001.
Under certain circumstances, we may not be able to tell you. This includes where:
- it would have an unreasonable impact on the privacy of other individuals;
- the information relates to legal proceedings with you;
- the information would reveal a commercially sensitive decision-making process; or
- we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.
We may charge a fee for accessing your personal information depending upon the circumstances. You will be advised at the time of your request of any applicable fee.
Cuscal will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. If at any time you believe that the information we hold about you is inaccurate, incomplete or out of date, please tell us by writing to the Privacy Officer, Cuscal Limited at GPO Box 4720 Sydney NSW 2001 and we will take all reasonable steps to correct our records.
Security of your personal information
We maintain strict procedures and standards and take all reasonable care to prevent unauthorised access to, and modification and disclosure of, your personal information. We will take all reasonable steps to protect your personal information from misuse and loss.
If we no longer need your information, we will destroy or de-identify it.
We will use your personal details to provide you with information, specific promotions and products that may be of interest to you (including products and promotions of our related companies). We may also provide your details to other organisations (including our related bodies corporate) for the purpose of these organisations marketing to you their products and services. If at any time you do not wish to receive further marketing information, you have the option to ask us not to send you any further information about products and services and/or not to disclose your information to other organisations for their marketing purposes. You may do this by writing to the Privacy Officer, Cuscal Limited at GPO Box 4720 Sydney NSW 2001.
Cuscal does not use your tax file number, Medicare number, pension number or any other government identifier to identify you. We only use and disclose these numbers for purposes required by law.
If you believe that the privacy of your personal information is not being adequately protected, you should contact us by telephoning the Privacy Officer on (02) 8299 9000. We will make every effort to resolve your complaint internally.
If we do not resolve your complaint to your satisfaction, you may wish to escalate the complaint to our external dispute resolution service free of charge.
You can engage the Australian Financial Complaints Authority (AFCA) and their contact details are as follows:
Time limits may apply to complain so you should act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.