Privacy and Credit Reporting Policy
Us, We or Our means W Coogan & Co PTY LTD trading as Coogans Stores.
You or Your means the customer.
Our Premises means 79 Collins Street, Hobart Tasmania 7000 and 21 Charles Street Moonah Tasmania 7009.
We are bound by the Privacy Act 1988 (Cth) (Privacy Act).
On 12 March 2014:
- a) 13 Australian Privacy Principles (APPs) replaced the existing National Privacy Principles (NPPs) in the Privacy Act; and
- b) a new Part IIIA was inserted into the Privacy Act to allow for more comprehensive credit reporting. The changes are designed to provide a more complete picture of Your credit profile and give financial institutions information to help them make a more informed decision about credit applications.
We are committed to complying with Our obligations under the Privacy Act (including the APPs). Our staff are trained to protect Your personal information in accordance with Our policies, procedures and systems.
This policy outlines how We will manage and secure Your personal information. It also describes the kinds of personal information that We hold and for what purposes, and how that information is collected, held, used and disclosed.
This policy also includes Our credit reporting policy. It contains additional information on how We manage Your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information below as credit information.
This policy is easy to access and is available on Our website at https://www.cooganstores.com.au/index.php/privacy-policy. You may request a copy of this policy by contacting the Privacy Officer in accordance with paragraph 15 of this policy.
Please read the policy before You provide Us with any personal information.
We will review this policy from time to time. We encourage You to check Our website regularly as any updated policy will be available on Our website.
What type of personal information do We collect and hold?
The types of personal information We may collect and hold about You may include:
- a) name, postal address, email address; telephone numbers, sex; date of birth;
- b) employment and income details;
- c) drivers licence number;
- d) Centrelink identification number;
- e) Medicare number;
- f) passport number;
- g) marital status;
- h) car registration number;
- i) real estate agents name & phone number;
- j) billing and payment details;
- k) any compliant details;
- l) name, address and phone number of 2 contacts; and
- )credit information such as details relating to credit history, credit capacity, and eligibility for credit.
When You apply for credit, We need to know if You will be able to meet repayments under Your credit contract with Us. As such, We need to obtain a credit report about You.
Credit reports contain information about Your credit history which help Us to assess Your credit application, verify Your identity and manage the accounts You hold with Us. Credit reporting bodies can collect and disclose this information with Us and other credit providers in certain circumstances, including when You make an application for credit or when We seek to help You avoid defaulting on Your credit obligations. .
The Privacy Act limits the information that credit providers can disclose about You to credit reporting bodies, as well as the ways in which credit providers can use credit reports.
In order to assess Your credit worthiness, We may collect information about You from, and give it to, credit reporting bodies. This information may include:
- a) Your identification information (including Your full name, an alias or previous name; date of birth, sex, Your current or last known address, 2 previous
addresses (if any), name of current or last known employer and drivers licence number);
- b) Your consumer credit liability information (including certain details relating to Your consumer credit such as the name of the credit provider, whether the credit provider has an Australian Credit Licence, the type of consumer credit, the day on which the consumer credit was entered into and terminated, certain repayment terms and conditions and the maximum amount of credit available);
- c) Your repayment history information (including whether or not You have made monthly payments and when they were paid)
- d) an information request (e.g. where a credit provider has asked a credit reporting body for information in relation to a credit application, including the type and amount of credit applied for);
- e) Your default information (including information about Your payments being overdue);
- f) Your payment information (including if a credit provider has disclosed default information about You to a credit reporting body and the overdue amount is paid, a statement that the payment has been made);
- g) Your new arrangement information (including if a credit provider has disclosed default information about to a credit reporting body about You and Your consumer credit contract is varied or replaced, a statement about this);
- h) court proceeding information (i.e. an Australian court judgment relating to Your credit);
- i) Your personal insolvency information;
- j) publicly available information that relates to Your activities in Australia and Your credit worthiness; and
- k) serious credit infringement information (i.e. a record of when a credit provider reasonably believes that You have committed a serious credit infringement (such as fraud).
Please note that information We obtain from credit reporting bodies or information We derive from such information is known as credit eligibility information.
We may need to collect sensitive information about You. Unless required by law, We will only collect sensitive information about You with Your consent where that information is reasonably necessary for Our functions.
Sensitive information is personal in nature. It is:
- a) information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation and/or practices, criminal records;
- b) health information about an individual; or
- c) genetic information about an individual that is not otherwise health information.
We may collect and hold the following types of sensitive information:
- a) health information; and
- b) criminal records.
If You use the internet to access Our website or transact with Us, We monitor Your use of Our website to ensure We can verify You and You can receive information from Us, and to identify ways We can improve Our services to You.
Some examples of an online transaction include:
- a) purchasing a product;
- b) registering as a customer;
- c) completing an online form; and
- d) subscribing to a newsletter or document.
If You start but do not submit an online application or order, We may contact You using any of the contact details You provided to offer help completing it.
We may use the data to collate statistics about You in order to continually improve web services but any statistics will not contain identifiable information.
When You visit Our websites, We automatically record:
- a) Your IP address;
- b) the date and time of Your visit;
- c) the pages You access; and
- d) the documents you download.
These statistics tell Us how Our site is being used and help Us to continually improve Our web services. The information collected does not identify you personally.
Some customers choose to engage with Us through social media channels. We may collect information about You when You interact with Us through these channels. Please note that We will only interact with You on confidential matters via a secure forum.
Collecting Your information
We collect Your personal information so that We can perform Our functions and activities.
We will, if it is practicable and reasonable to do so, collect personal information directly from You. This may happen when:
- a) You fill out a form (i.e. change of address form, customer care form, amendment to credit contract form, credit declaration);
- b) You give Us personal information over the telephone;
- c) You interact with Us electronically or in person;
- d) You access Our website; or
- e) We supply goods to You.
We may also collect information about You from other sources where it is necessary to do so. This may also include:
a)accessing information about You that is publicly available on the electoral roll, telephone directories and other websites etc;
b)collecting information from organisations who have authority to act on Your behalf;
c)collecting information from a third party where We provide finance to You to purchase goods or services from that third party.
If You do not provide Your personal information to Us, We may not be able to:
- a) provide You with the product or service You want;
- b) verify Your identity; or
- c) manage Your account.
We will collect Your credit information from details included in Your credit application. This may happen in paper form, electronic form, in person or over the telephone.
We may also collect credit information from the following third parties:
- a) credit reporting bodies if We request a report about Your credit history;
- b) other credit providers if We request information from them about the products they provide to You; and
- c) debt collecting agencies.
We may collect information from You because We are required by an Australian law or court/tribunal order to collect that information. The National Consumer Credit Protection Act 2010 (Cth) requires credit providers like Us to make inquiries into the financial situation, needs and objectives of individuals who apply for credit. This is to ensure that We have enough information to make an informed decision about whether the individual can afford the credit they are applying for.
Purposes for collecting, holding, using and disclosing information
We collect, hold, use and disclose Your personal information (including credit information) for the following purposes:
- a) to assess Your credit worthiness for providing or extending credit;
- b) to consider Your request for a product or a service;
- c) to enable Us to provide You with a product or a service;
- d) to process Your credit application;
- e) to inform You about other products and services that may be of interest to You;
- f) to assist Us to contact You;
- g) billing purposes;
- h) to assist with debt collection/skip tracing;
- i) to consider hardship requests;
- j) to arrange payment plans;
- k) to manage accounts and perform administrative and operational tasks;
- l) for product warranty, claim and repair purposes;
- m) to freight goods;
- n) to enable a Tradesperson or business other than Us to install goods;
- o) marketing (direct, indirect, inbound and outbound) purposes;
- p) to make arrangements with other organisations who have authority to act on Your behalf
- q) to collect overdue payments;
- r) dispute resolution purposes;
- s) to manage and deal with any possible legal actions;
- t) as required by any applicable laws, regulations or codes of practice;
- u) for IT system development and testing where Our internal computer system is upgraded;
- v) to deal with any insurance claims; and
- w) any other purpose for which You have given Your consent.
Use and disclosure of personal information
Personal information We hold about You that was collected for a particular purpose will not be disclosed for another purpose unless:
- a) You have consented to the use or disclosure of the information for another purpose; or
- b) the access, use or disclosure is otherwise permitted under the Privacy Act.
Where Your personal information is disclosed, We will seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.
We are not likely to disclose Your personal information (including credit information) to any overseas organisations or entities.
Use and disclosure of credit information
We will not use or disclose credit information unless the use or disclosure is permitted under the Privacy Act.
We may disclose personal information about You to third parties, including:
- a) credit reporting bodies if You are applying for credit or You have obtained credit from Us;
- b) credit providers;
- c) debt collection agencies;
- d) Our legal representatives;
- e) Our external dispute resolution scheme, the Financial Ombudsman Service;
- f) organisations who have authority to act on Your behalf;
- g) a third party where We provide finance to You to purchase goods or services from that third party; and
- h) any other person where You have given Your consent.
As outlined above, We may disclose your credit information to credit reporting bodies. The contact details of the credit reporting bodies We use are outlined below:
Veda Advantage Ltd
Ph: 1300 850 211
Mail: Veda Information Services & Solutions Ltd
PO Box 964
North Sydney NSW 2059
Email: [email protected]
Tasmanian Collection Service
Ph: 03 6213 5555
Mail: Po Box 814H
Hobart TAS 7001
Email: [email protected]
Each of the above credit reporting bodies has a credit reporting policy about how they deal with Your credit information. For more information, or to request a copy of their credit reporting policy, You can contact them directly.
We may use or disclose Your personal information for direct marketing purposes. However, You can contact Our Privacy Officer in accordance with paragraph 15 at any time to let Us know that You do not want to receive marketing material from Us.
You may opt-out of receiving any more marketing or promotional literature.
All Our marketing correspondence will display a clearly visible and user-friendly opt-out tick box. We may imply consent to receive marketing material if You do not tick the opt-out box.
If You request to no longer receive direct marketing material We will process Your request within a reasonable period after the request is made.
A credit reporting body may use credit information it collects about You to pre-screen You for direct marketing at the request of a credit provider. The credit reporting body uses this information to assess whether or not You are eligible to receive direct marketing from the credit provider. You can ask a credit reporting body not to do this.
Quality of personal information
We must take reasonable steps to ensure that any personal information (including credit information) We collect, use or disclose is accurate, complete, up-to-date and relevant to Our functions or activities.
If You believe that Your personal information is not accurate, complete or up to date, please contact the Privacy Officer in accordance with paragraph 15 of this policy.
Security of personal information
We store Your personal information (including credit eligibility information) in different ways, including in paper and electronic form.
We treat all personal information as confidential. We will take all reasonable steps to ensure personal information is protected from:
- a) misuse, interference and loss; and
- b) unauthorised access, modification and disclosure.
Some of the ways We do this are:
- a) storing electronic documents, records and information within Our secure computer system, which is located behind a firewall;
- b) making access to personal information only available to approved users with a username and password log in facility;
- c) using secure methods of communication;
- d) using antivirus, antispyware and https protocols where possible;
- e) using back-up and recovery systems;
- f) storing hard copies of personal information on Our Premises in secure areas with restricted access;
- g) making employees sign confidentiality agreements;
- h) using an independent security firm to monitor Our premises 24 hours a day; and
- i) video surveillance on restricted areas.
If We no longer need Your personal information for any purpose, We will take reasonable steps to destroy or permanently de-identify the information, unless:
- a) the information is contained in a Commonwealth record; or
- b) We are required by law, or a court/tribunal order, to retain the information.
Access to personal and credit information
You can access Your personal information (including credit eligibility information), unless an exception in the Privacy Act applies.
You can request access to Your personal information and credit information by contacting Our Privacy Officer in accordance with paragraph 15 of this policy.
We will need to verify Your identify before giving You access.
In some cases We will deal with Your personal information request immediately. However, if the request is more complex, We will:
- a) respond to Your request within a reasonable time (usually within 30 days); and
- b) give You access to Your information in the manner You request, provided it is reasonable and practical to do so.
Depending on the nature of the request, We may charge You a small fee for giving You access.
In some instances, We may not be able to provide the information requested. If this occurs, We will:
- a) take such steps as are reasonable to give access in a way that meets Our needs as well as Yours;
- b) provide You with written reasons for the refusal provided it is reasonable to do so; and
- c) provide You with the mechanisms available to complain about the refusal.
If You request access to credit eligibility information, We must:
- a) take reasonable steps to provide an accessible means for You to obtain access to the information;
- b) provide access within 30 days of the request (unless unusual circumstances apply);
- c) make the information clear and accessible;
- d) provide reasonable explanations and summaries of the information; and
- e) ask You to check with credit reporting bodies what information they hold about You to ensure that You have access to the most up-to-date information.
If We refuse to give You access to any credit eligibility information, We will give You a written notice that:
- a) sets out the reasons for the refusal provided it is reasonable to do so; and
- b) states that, if You are not satisfied with the response to the request, You may complain to Our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Correction of personal information
If You think any personal information (including credit information) We hold about You is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, You may request Us to correct the information by contacting the Privacy Officer in accordance with paragraph 15 of this policy.
We will need to verify Your identify before correcting Your information.
We must take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
- a) We correct personal information (including identification information) that has been disclosed to another entity; and
- b) You request that We notify the other entity of the correction,
We will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.
If We refuse to correct the personal information, then We will provide You with:
- a) written reasons for the refusal provided it is reasonable to do so; and
- b) the mechanisms available to complain about the refusal; and
We will respond to Your request to correct personal information within a reasonable time (usually within 30 days).
Correction of credit information
We must do some additional things if You ask Us to correct credit information.
We will take reasonable steps to correct Your credit information within 30 days from the day on which the request is made (or such longer period as You have agreed in writing).
Where necessary to resolve the correction request, We will consult other credit reporting bodies or credit providers.
We do not charge You a fee for making a request to correct information.
If We correct credit information that We have previously disclosed to a third party, We will give each recipient of the information written notice of the correction within a reasonable period, unless it is impracticable and unlawful to do so.
If We correct Your credit information, We will provide You with a written notice of the correction within 5 business days.
If We refuse to correct the credit information, then We will provide You with a written notice that:
- a) states that the correction has not been made;
- b) sets out the reasons for the refusal provided it is reasonable; and
- c) states that if You are not satisfied with the response to the request, You may access Our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.
You have the option to remain anonymous, or to use a pseudonym when dealing with Us where it is lawful and practical to do so.
Complaints or disputes
- a) You have any issues about the way We handle Your personal information after reading this policy;
- b) You become aware of a potential breach of Your privacy; or
- c) wish to make a complaint, please contact Our Privacy Officer as set out below.
Complaints are to be directed to:
Privacy Officer - Administration Manager
Ph: 03 62331854
Email: [email protected] or [email protected]
If Our Privacy Officer is unable to resolve the matter, it will be escalated (internally or externally) as appropriate to facilitate resolution.
If You are not satisfied with the outcome of Our investigation, the complaint may be taken to the following external dispute resolution scheme of which We are a member:
Financial Ombudsman Service
Ph: 1300 780 808
Email: [email protected]
Alternatively, You may take the complaint to:
the Office of the Australian Information Commissioner (OAIC)
Ph: 1300 363 992
Email: [email protected]
Additional considerations for managing complaints about credit information
If Your compliant relates to how We have handled Your access and correction requests, You may take Your compliant directly to:
- a) Our external dispute resolution scheme; or
- b) OAIC.
If You make a complaint about credit information (other than access or correction requests), We will give You a notice letting You know how We will deal with it within 7 days.
If a decision about the compliant cannot be made within 30 days, We will ask You for an extension of time to resolve the compliant.
A decision must be made in relation to the complaint within 30 days or longer period agreed to by You in writing. If You have any concerns You may complain to Our external dispute resolution scheme or the OAIC.
Government related identifiers
In certain circumstances We may be required to collect government related identifiers, such as Your driver’s licence number, Centrelink identification number, Medicare number and passport number.
We will not use or disclose this information unless an exception in the Privacy Act applies.
Last updated in April 2014