We, Transcomm Credit Co-operative
Limited, recognise the importance of your
privacy, and are committed to protecting
personal information about you that we hold.
This Privacy Policy describes how we manage
your personal information and safeguard
your privacy.
1.
National Privacy Principles
From
21 December 2001, most private sector organisations
in Australia must by law comply with the
National Privacy Principles ("NPPs").
The NPPs strengthen protection of your privacy.
We will comply with the NPPs from that date
2.
Collecting
personal information about you
We hold only those
kinds of personal information that are necessary
for us to perform our functions and to comply
with the law. This in turn depends
upon the type of product or service you
request from us. It may include:
| 2.1 |
Information
you give us when you apply for or request
a product or service from us.
The information will include your name,
address and contact details. If
you fail to give us the information
we ask for, we may be unable to process
your request for a product or service. |
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| 2.2 |
Financial
information about you, such as your
financial position. We will only
hold information obtained from credit
checks if you have authorised us to
carry out those checks. |
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| 2.3 |
Communications
between you and us. |
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| 2.4 |
Transactional
information about a product or service
you have or had with us. |
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We may also
collect some information about you
when you use our website "transcomm.com.au")
("the website"). If you
visit the website and subsequently
download and complete a form such
as membership application form or
loan application form or to send us
an email with your personal details,
we will record the information you
give us, including your email address.
Thus, your
use of the facilities and information
available on the website will determine
the type and amount of personal information
we collect about you.
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3. Using
and disclosing your personal information
| 3.1 |
We
respect your privacy. Any personal
information which we collect about
you will be used by us to:
| (a) |
provide
you with the products or services
you have requested, and/or |
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| (b) |
assess
an application by you for products
or services we may provide and
if that application is approved,
to provide them to you. |
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In addition,
we may also use your personal information
to provide you with information about
other products and services offered
or distributed by us or our related
companies, Transcomm Financial Planning
Pty. Ltd. or Transcomm Financial Services
Pty. Ltd. However we will only
do this with your consent. We do not
use external identifiers to assist us
in the management of personal information. |
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| 3.2 |
We store your
personal information with a strong emphasis
on its security and the protection of
your privacy. In considering the
security of your personal information,
we have taken into account: |
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| (a) |
Physical
security: |
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| (i) |
All
files containing personal
information are stored in
locations which is not accessible
by members of the public. |
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| (ii) |
All
files containing personal
information are accessible
only by staff requiring
them for the completion
of specific duties. |
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| (iii) |
All
hard copies of identification
items such as passports
and drivers licences are
destroyed by means of a
secure destruction service
after the entry onto the
database of the information
they contain and where they
are no longer required. |
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| (iv) |
Drafts,
spare copies and extra materials
generated in the handling
of files containing personal
materials are destroyed
by means of a secure destruction
service. |
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| (v) |
Personal
information that is no longer
required is permanently
de-identified or destroyed
by means of a secure destruction
service. |
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| (vi) |
Information
about closed accounts is
held for seven years at
a secure off site facility
and at the end of the seven
year period the information
is destroyed by means of
a secure destruction service. |
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| (b) |
Computer
and network security: |
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| (i) |
Access
to the computer network
is by user identification
and password only.
Passwords are changed regularly.
The system administrator
can identify all users by
their user identification. |
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| (ii) |
The
System Administrator and
Senior Management regularly
review computer records
for security breaches and
reports any breaches to
the General Manager and/or
CEO. |
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| (iii) |
Computer
files are regularly reviewed
for continued relevance
by a staff member with appropriate
security clearance and where
necessary deletion and purging
of files no longer required
is undertaken on a system
wide basis. |
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| (iv) |
Files
are regularly backed up
and saved at a separate
and secure site. |
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| (v) |
Network
security includes firewall
and virus protection and
network intrusion detection
systems |
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| (c) |
Communications
security: |
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| (i) |
No
personal information is
provided at branches, over
the telephone or by facsimile
until the identity of the
applicant is verified. |
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| (ii) |
Access
to telephone banking is
password protected. |
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| (d) |
Personnel
security: |
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| (i) |
Hard
file and computer copies
of unsuccessful applications
for employment are destroyed
by means of a secure destruction
service. Appropriate
and lawful enquiries are
made before an offer of
employment is made to any
person. |
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| (ii) |
Access
to your personal information
is given to staff strictly
on the basis of their need
to have access to the material
in order to fulfil their
function within the credit
union. |
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| 3.3 |
In order
to provide you with the products
and services you want and also
information about these and other
products and services offered
or distributed by us or our related
companies, we may disclose your
personal information to: |
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our
related companies Transcomm
Financial Planning Services
Pty. Ltd. and Transcomm Financial
Services Pty. Ltd.
organisations
to whom we contract out functions
such as
mailing houses;
storage
and archiving services
solicitors
general
insurers
mortgage
insurers
plastic
card and Personal Identification
Number (PIN) providers
cheque
book and deposit book printers
car
buying/search services
property
valuer |
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| 3.4 |
We contract
out some of our functions, as
mentioned above, to external service
providers. We may disclose
your personal information to them
so that they can provide the services
we have contracted out to them.
Where possible, all our service
providers are subject to the NPPs
or to contractual arrangements
imposing substantially similar
obligations. |
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| 4. Access
to your personal information |
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| 4.1 |
From 21 December
2001, in most cases, you can gain access
to personal information we hold about
you. We will handle requests for
access to your personal information
in accordance with the NPPs and subject
to current legislation. All requests
for access to your personal information
will be handled by our Operations Manager,
who can be contacted by telephone or
in writing at the telephone number and
postal and email addresses set out in
item 5 below. |
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| 4.2 |
We will deal
with all requests for access to personal
information as quickly as possible.
In any event, we will make an initial
response to your request within 30 days.
Requests for large amounts of information,
or for information not currently in
use, may require some time before a
full response can be given. |
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| 4.3 |
In some
circumstances under the NPPs we may
refuse to give you access to personal
information we hold about you.
These are circumstances where giving
you access would: |
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| (a) |
pose a serious
and imminent threat to the life
or health of any individual; |
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| (b) |
have an unreasonable
effect upon the privacy of other
individuals; |
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| (c) |
give you access
to material which would not be
accessible by the process of discovery
in existing or anticipated legal
proceedings between you and us; |
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| (d) |
reveal our
intentions in relation to negotiations
with you in such a way as to prejudice
those negotiations; |
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| (e) |
be unlawful; |
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| (f) |
be likely to
prejudice an investigation of
possible unlawful activity, or |
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| (g) |
be likely to
prejudice: |
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| (i) |
the prevention,
detection, investigation,
prosecution or punishment
of criminal offences, or
certain other breaches of
law; |
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| (ii) |
the enforcement
of laws relating to the
confiscation of the proceeds
of crime; |
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| (iii) |
the
protection of the public
revenue; |
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| (iv) |
the prevention,
detection, investigation
or remedying of seriously
improper conduct or prescribed
conduct, or |
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| (v) |
the
preparation for, or conduct
of, proceedings before
any court or tribunal,
or implementation of its
orders;
by or on behalf of an
enforcement body.
We may also refuse access
if:
· we
consider the request for
access is frivolous or
vexatious;
· we
are required or authorised
by or under law to do
so, or
· an
enforcement body performing
a lawful security function
asks us not to do so,
on the basis that to do
so would be likely to
cause damage to the security
of Australia.
If
we refuse to give you
access to the personal
information you request,
we will under the NPPs
provide you with reasons
for our refusal. |
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| 4.4 |
We wish to
ensure that your personal information
is accurate, complete and up to
date. Generally, if you
request us to do so, we will amend
any personal information about
you that is inaccurate, incomplete
or out of date. If we disagree
with you about any of these matters,
and if you request us to do so,
we will take reasonable steps
to associate a statement to the
effect that you claim the information
to be inaccurate, incomplete or
out of date with your personal
information. |
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| 4.5 |
There will
be no charge for lodging a request
for access to personal information.
However, we may charge you for
providing access. Any charges
will not be excessive. A
schedule of current charges is
available upon request at our
branch. |
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| 5.
Contacting us for further information |
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You can get more
information about the way we manage
your personal information by
contacting us at the telephone number,
postal or email addresses set out
below.
If you are concerned
that we may have breached your privacy
and wish to make a complaint, please
contact us at the telephone number,
postal or email addresses set out
below.
Contact
details
For access
to your personal information or to
request a change to personal information
held,
or
To receive
further information about the way
we manage personal information
Contact:
Operations Manager
99 King Street
Melbourne 3000
Phone : 03 9629 4484
To complain about a breach of privacy
Contact
:
Company Secretary
99 King Street
Melbourne 3000
Phone : 03 9629 4484
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| 6. Changes
to our privacy policy |
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From time
to time it may be necessary for us to review and revise our privacy
policy. We reserve the right to change our privacy policy
at any time.
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