Privacy policy

Who are we?

‘We’, ‘us’ and ‘our’ refer to Good Shepherd Microfinance ABN: 36 151 124 408, Australian Credit Licence 492819 (including all trading brands). Good Shepherd Microfinance is the issuer of Speckle loans.

Our commitment to protect your privacy

We understand how important it is to protect your personal information.  This document sets out our privacy and credit reporting policy commitment in respect of personal information we hold about you and what we do with that information including credit information.

We recognise that any personal information we collect about you should be protected and will only be used for the purposes for which we have collected it 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 1998 (Cth) (as amended) (Privacy Act) and any other relevant law.

What types of information do we collect?

Personal information is 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. Identification information, such as your name (including prior names and aliases), residential, postal and email address, telephone numbers, date of birth, gender, drivers license number, accounts details, occupation,  and any other information we may need to identify you. The kinds of personal information we may collect about you includes your name, date of birth, address, account details, occupation, and any other information we made need to identify you or use for the purpose of arranging and providing  credit to you and for managing that credit.
  • health information; and
  • Credit information including a credit opinion of you (collectively personal information)

Credit information is information which is used to assess your eligibility to be provided with finance and the management of that finance and may include:

  • any finance that you have outstanding, your repayment history in respect of those loans, and any adverse credit information held by us or a credit reporting body; 
  • information from a credit reporting body including, scores, ratings, summaries, credit enquiries, repayment history, credit defaults and judgements;.
  • financial details such as, employment details, proof income and expenses, length of time at current residential address and number of dependents;
  • 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; and
  • personal insolvency information (collectively credit information)

Why we collect your personal information?

We collect personal information for the purposes of assessing your application for finance, and managing that finance (including any default or collection activities) and to meet any legal or regulatory compliance obligations imposed on us by any law or government agency.  By Commonwealth anti-money laundering law we require personal information to verify your identity. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you.  From time to time we may offer you other products and services.

Your account and credit information may also be used for the purpose of repayment, default and collection administration where such a situation exists in the management of your finance.

We also collect personal information to enable us to participate in the credit reporting system and to provide information to credit reporting bodies as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code.

How do we collect your personal information?

Where reasonable and practical we will collect your personal information directly from you.  There are many ways we can collect information from you such as, via our website, email, SMS, letters, web chat and telephone.

We also collect information from credit reporting bodies and other credit providers, from publicly available sources of information and from information derived by us from your conduct.

Do we disclose your personal information?

We use your information to access and provide you with the financial product you have requested

We may disclose your personal information:

  • to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
  • to credit reporting bodies and other credit providers;
  • 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 Counter- Terrorism Financing Act 2006 (Cth);
  • to investors, agents or advisers, or any entity that has an interest in our business; or
  • to your employer, referees for identity and income  verification services in respect of for your employment details.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

  1. the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
  2. you have consented to us making the disclosure.

Sharing your credit information

We may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities:

  • credit liability information, being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;
  • repayment history information, which is information about whether you meet your repayments on time;
  • information about the type of finance that you are applying for;
  • new arrangement information, which includes information about a variation to existing liabilities;
  • default and payment information, which includes payments that are more than 60 days overdue and whether they have been made;
  • personal insolvency information, which is information that is entered into the National Personal Insolvency Index which relate to such things as debt agreements, bankruptcy personal insolvency agreements; and
  • court proceedings information.

We exchange this credit information for the purposes of assessing your application for finance, managing that finance, discharging our functions under the Bankruptcy Act 1966 (Cth) or administering your debt agreement.

This credit information may will be held by us in electronic form on our secure servers and may also be held in paper form.  We may use cloud storage to store the credit information we hold about you.

When we obtain credit information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

Notifiable matters

The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information.  You may request to have these notifiable matters (and this privacy and credit reporting policy) provided to you in an alternative form.

We exchange your credit information with credit reporting bodies.  We use the credit information that we exchange with the credit reporting body to assess your creditworthiness, assess your application for finance, manage your finance, and administer your debt or personal insolvency agreement.

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 credit information that we hold about you and make a request for us to correct that credit information if needed.  Please see the heading “Access and correction to your personal and credit information”, below.

Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers.  You can contact the credit reporting body at any time to request that your credit information is not used in this way.

You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud.  For a period of 21 days after the credit reporting body receives your notification the credit reporting body must not use or disclose that credit information.  You can contact any of the following credit reporting bodies for more information via their websites at:

Direct marketing

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 telephoning us on 13 43 23 or by writing to us at P.O. Box 12059, A’ Beckett Street VIC, 8006.

If the direct marketing is by email you may also use the unsubscribe function. If the direct marketing is by text you may also use the unsubscribe function.

By using the unsubscribe function in a direct marketing communication you will only unsubscribe from direct marketing from that method of delivery.  Please let us know if you would like to unsubscribe from all direct marketing from Speckle and related entities.  We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

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 credit 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 an administration fee for 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 information we hold about you.

If any of the personal or credit 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 information within 30 days.

We may need to consult with other entities as part of our investigation.

If we refuse to correct personal 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, we do not use or disclose this information other than as 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 fee charges or current promotional offers.

Sensitive information

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.

Complaints

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, you may contact our complaints officer by telephone on 13 43 23 or by email at [email protected].  You may also mail a written complaint to the following address:

The Privacy Officer
Speckle
P.O. Box 12059, A’ Beckett Street VIC, 8006

We will acknowledge your complaint within seven days of the date we receive it.  We will provide you with a decision on your complaint within 30 days.

If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted via the Office of the Australian Information Commissioner website (www.oaic.gov.au) or on 1300 363 992.

Further information

You may request further information about the way we manage your personal information by contacting us.

Change in our privacy and credit reporting policy

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.

As a consequence we may change this privacy policy from time to time or as the need arises.

You may request this privacy policy in an alternative form.

This privacy and credit reporting policy came into existence on 1 June 2017