Privacy & Credit Reporting Policy

Important information relating to credit reporting

Effective from 3 May 2016

This information applies to Commercial Distribution Finance Pty Ltd ABN 53 086 920 747 and GE SPA Leasing Pty ABN 75 095 668 036.

This statement sets out important information about credit reporting that is relevant to you if:

    • you are an individual applying for credit, or who holds a credit product, from any of the GE Companies described at the end of this statement (collectively referred to in this statement as "we"/"us"); or
    • we deal with you in connection with credit applied for by, or provided to, another customer - for example, if you are a guarantor or proposed guarantor for that credit or if you are a director of a company obtaining credit.
  • We may disclose your personal information to credit reporting bodies: We may disclose personal information about you in connection with your credit-related dealings with us to credit reporting bodies. Those credit reporting bodies may include that information in reports that they provide to other credit providers to assist them to assess your credit worthiness.
    For example, if you fail to meet your payment obligations to us in relation to consumer credit, or if you commit a serious credit infringement in relation to consumer credit provided by us, we may be entitled to disclose this information to credit reporting bodies.
  • We disclose information to the following credit reporting bodies:

    • Dun and Bradstreet (Australia) Pty Ltd (for our Commercial Finance entities)
      Website: www.checkyourcredit.com.au
      Postal address: PO Box 7405, St Kilda Road, Melbourne, VIC 3004
    • Veda Advantage Information Services and Solutions Limited (for our Commercial Finance entities)
      Website: www.veda.com.au
      Postal address: PO Box 964, North Sydney, NSW 2059

    These credit reporting bodies are each required to have a policy which explains how they will manage your credit-related personal information. To view the policy of any of these credit reporting bodies please visit the relevant credit reporting body's website and follow the "Privacy" links, or you can contact them directly for further information.

  • Excluding your credit reporting information from direct marketing pre-screening:
    You have the right to request that a credit reporting body exclude your credit reporting information from being used by them in connection with pre-screening for direct marketing requested by a credit provider. You should contact each relevant credit reporting body directly if you wish to request this.
  • Protecting your credit reporting information if you are the victim of fraud:
    You have the right to request that a credit reporting body not use or disclose your credit reporting information if you believe that you have been, or are likely to be, the victim of fraud (for example, if you suspect that someone is using your identity details to apply for credit). You should contact each relevant credit reporting body directly if you wish to request this.
  • Accessing or correcting your personal information or making a privacy complaint:
    You have rights to request access to, or correction of, personal information that we hold about you, including credit-related information. You also have rights to make a complaint if you consider that we have not complied with the Privacy Act in relation to this information. Our Credit Reporting Policy (please see below) sets out how you can make such requests or complaints and how we will deal with them.

For details about how we manage credit-related personal information (including credit reporting information) that we hold about you, please see our Credit Reporting policy.

GE Companies

Commercial Finance entities

  • Commercial Distribution Finance Pty Ltd ABN 53 086 920 747
  • SPA Leasing Pty ABN 75 095 668 036

This statement may also apply to other entities in the GE group who are credit providers, or who receive credit eligibility information under the Privacy Act from time to time.

Credit Reporting Policy

Credit Reporting Policy (including important information about how credit reporting affects you)

Effective from 3 May 2016

This policy applies to Commercial Distribution Finance Pty Ltd ABN 54 608 590 727 and GE SPA Leasing Pty 75 095 668 036.

At GE we take our obligations to protect personal information about individuals, including credit information and credit eligibility information, seriously.

The GE Companies described at the end of this policy (collectively referred to in this policy as "we"/"us") are bound by Part IIIA of the Privacy Act 1988 (Cth) ("Privacy Act") and the 'Credit Reporting Privacy Code', which govern credit reporting in Australia.

About this Credit Reporting Policy

The purpose of this Credit Reporting Policy is to tell you how we manage:

  • credit information - this information relates primarily to your credit-related dealings with us and we can disclose this information to credit reporting bodies. For a list of what is credit information see '1. What kinds of credit information do we collect and hold?' below;
  • credit eligibility information - this information relates primarily to your credit-related dealings with other credit providers. Credit eligibility information comprises:
    • 'credit reporting information' provided by credit reporting bodies (for a more detailed explanation see '3. Exchanges of information about you with credit reporting bodies' below); and
    • credit worthiness information that we derive using "credit information" (for a more detailed explanation see '4. What kinds of credit worthiness information do we derive from credit reporting information?' below).

The Privacy Act contains a variety of detailed definitions describing these types of information. To make it easier for you to read this policy we have only included some general explanations above. If you would like to refer to the full provisions in the Act and or the Credit Reporting Privacy Code they are available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

This Policy explains:

  • the kinds of credit information and credit eligibility information that we collect and hold;
  • how we collect and hold credit information and credit eligibility information;
  • the purposes for which we collect, hold, use and disclose credit information and credit eligibility information;
  • how you may access your credit information and credit eligibility information held by us or request correction of that information;
  • how to make a complaint if you consider that we have not complied with Part IIIA of the Privacy Act or with the Credit Reporting Privacy Code, and how we will deal with such complaints; and
  • the circumstances in which we may disclose credit information and credit eligibility information to overseas recipients and the countries where such recipients may be located.

This Policy applies to any individual in relation to whom we hold credit information or credit eligibility information no matter how they interact with us (e.g. on-line, in person or over the phone). The latest version of this Policy will be published on our websites.

Please note that if you apply for, or have obtained, commercial credit from us, this Policy does not deal with the way we exchange commercial credit information with commercial credit reporting bodies.

For information about how we manage other personal information about you please see our Privacy Policy available on our website(s).

  1. What kinds of credit information do we collect and hold?

  2. At GE, we collect and hold your credit information, examples of which include:

    • Identification information, such as your name, address, date of birth or employer.
    • Consumer credit liability information. This is information about consumer credit accounts you hold, or have held, with us, such as the type of account, the date the account was opened and closed, the maximum amount of credit approved for that account and some specific terms and conditions relating to the repayment of credit under that account.
    • A note that we have made an information request about you with a credit reporting body. An information request is when we ask a credit reporting body to provide us with credit reporting information about you.
    • The type of credit and the amount of credit sought in an application for credit made by you in connection with which we made an information request.
    • Default information about you. This is information about a payment owed by you as a borrower or guarantor in connection with consumer credit that remains overdue for more than 60 days and which we can disclose to a credit reporting body if certain requirements under the Privacy Act are met.
    • Payment information about you. Payment information is a statement that an overdue payment in relation to which default information was provided to a credit reporting body has been paid.
    • Court proceedings information about you. This is information about a judgment of an Australian court that is made against you that relates to credit that was provided to, or applied for, by you.
    • Personal insolvency information about you. This is information recorded in the National Personal Insolvency Index and relating to your bankruptcy, a debt agreement proposal given by you, a debt agreement made by you, a personal insolvency agreement executed by you, a direction given, or an order made, under the Bankruptcy Act that relates to your property or an authority signed under the Bankruptcy Act that relates to your property.
    • Publicly available information about you:
      • that relates to your activities in Australia or the external territories and your credit worthiness; and
      • that is not court proceedings information about you or information about you that is entered or recorded in the National Personal Insolvency Index.
    • An opinion we have on reasonable grounds that you have committed a serious credit infringement in relation to consumer credit that was provided to you. A serious credit infringement includes, in summary:
      • that you were fraudulently obtaining (or attempting to obtain) consumer credit; or
      • that you are fraudulently evading (or attempting to evade) your consumer credit obligations; or
      • that you are no longer intending to comply with your consumer credit obligations as we have not been able to contact you for 6 months in accordance with the Privacy Act.
  3. How do we collect credit information?

    We collect credit information in a variety of ways, such as obtaining the relevant information directly from you or by persons acting on your behalf (including on application forms or other forms or in our ongoing dealings with you in connection with credit). Some credit information will also be derived by us from your transactions in connection with credit, such as when you make payments to us.

  4. Exchanges of information about you with credit reporting bodies
    We may obtain credit reporting information about you from credit reporting bodies. Credit reporting information includes:
    • credit information of the kinds listed under 'What kinds of credit information do we collect and hold?' but relating primarily to your dealings with other credit providers (such as about credit applications you have made or credit that you hold with other credit providers). This information will typically have been provided by other credit providers or other third parties; and
    • credit worthiness information about you that credit reporting bodies derive from the information above, such as credit scores, risk ratings and other evaluations about you.

    We may also disclose your credit information relating to your dealings with us to credit reporting bodies. Those credit reporting bodies may include that information in reports that they provide to other credit providers to assist them to assess your credit worthiness.

    For example, we will provide information that identifies you and about your application for credit when obtaining credit reporting information for the purposes of assessing that application.

    GE discloses credit information to the following credit reporting bodies:

    • Dun and Bradstreet (Australia) Pty Ltd Website: www.checkyourcredit.com.au
      Postal address: PO Box 7405, St Kilda Road, Melbourne, VIC 3004
    • Veda Advantage Information Services and Solutions Limited Website: www.veda.com.au
      Postal address: PO Box 964, North Sydney, NSW 2059

    These credit reporting bodies are each required to have a policy which explains how they will manage your credit-related personal information. If you would like to read the policies of these credit reporting bodies please visit their websites and follow the "Privacy" links, or you can contact them directly for further information.

    You have the right to request these credit reporting bodies to exclude your credit reporting information from any permissible direct marketing activities GE may request them to perform.

    You also have the right to request credit reporting bodies not to use or disclose your credit reporting information if you believe that you have been, or are likely to be, the victim of fraud (for example, you suspect someone is using your identity details to apply for credit). You must contact the credit reporting bodies directly should this be the case.

  5. What kinds of credit worthiness information do we derive from credit reporting information?
    We utilise credit reporting information obtained from credit reporting bodies to derive other information that assists us in assessing your creditworthiness, for example, credit risk ratings and credit scores.

  6. How do we hold and protect credit information and credit eligibility information?

    We understand the importance of protecting the personal information, including credit information and credit eligibility information, we hold. We take steps to ensure that this information is free from misuse, interference, loss, unauthorised access or modification. This includes:

    • securing information both in physical and electronic form;
    • having internal procedures and measures limiting access to personal information only to those that need access for their legitimate activities; and
    • protecting our systems by appropriate technology solutions.


  7. For what purposes do we collect, hold, use and disclose credit information and credit eligibility information?

    GE collects, holds, uses and discloses credit information and credit eligibility information about you for purposes reasonably necessary for our business activities and consistently with the requirements in the Privacy Act as permitted by law. These purposes include:

    • to assess applications for credit (including assessing any proposed guarantors);
    • for the ongoing servicing and administration of our accounts and products;
    • to assist with the management, including recovery, of outstanding debts;
    • to assist you if we consider that you may be at risk of default;
    • internal management purposes;
    • for data analysis;
    • to participate in the credit reporting system and provide information to credit reporting bodies as permitted by the Privacy Act;
    • to undertake securitisation activities and debt assignments;
    • to deal with complaints and legal proceedings;
    • to meet our legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies when authorised or required by law); and
    • to assist other credit providers with such purposes in circumstances permitted by the Privacy Act (such as disclosing information to another credit provider with your consent or where you have committed a serious credit infringement).

    Restrictions apply under the Privacy Act in relation to the circumstances and purposes for which such information may be used or disclosed and we comply with these restrictions. For example, credit eligibility information may not be disclosed to some types of overseas entities and restrictions apply on the use of credit eligibility information for direct marketing.

  8. Will we be disclosing your credit information or credit eligibility information to overseas organisations?

    As is the case throughout the Australian financial services industry (and other major industries), technology allows for services to be provided by different service providers including some that are located overseas. We utilise overseas service providers for some of our activities and to do so we may need to disclose credit information or credit eligibility information to those service providers. We may also disclose such information to other overseas recipients for the purposes listed above when permitted to do so by the Privacy Act.

    Whilst it is not practicable to list every country in which such recipients are likely to be located, it is likely that the countries to which your credit information or credit eligibility information may be disclosed include South Korea, China, Hungary, India, Japan, Mexico, New Zealand, Philippines, Poland, Singapore, Spain, United Kingdom, and the United States of America.

  9. How can you access credit eligibility information we hold about you?

    You may access the credit eligibility information which we hold about you by contacting us on the relevant contact number provided at the end of this Policy.

    We will need to verify your identity before giving you access. We will usually provide the information requested within 30 days of receiving your request. If there is a reason we are unable to agree to a request for access to your credit eligibility information we will advise you of this in writing.

    There is no charge to make a request for access request but we may apply an administration fee for providing access in accordance with your request.

  10. How can you seek correction of the credit information or credit eligibility information about you which we hold?

    We aim to hold accurate and up-to-date credit information and credit eligibility information about you at all times. If you consider that any such information we hold about you is incorrect in any way, you may seek the correction of that information.

    To seek such a correction please call the relevant contact number provided at the end of this Policy to discuss your query.

    In certain situations, we may not agree to a request to correct information we hold about you. If this occurs we will advise you of this and our reason for not agreeing to the correction request in writing.

  11. How can you make a complaint about our compliance with our credit reporting obligations and how will we deal with such a complaint?

    If you believe that we have failed to comply with the credit reporting requirements in Part IIIA of the Privacy Act or the Credit Reporting Privacy Code, please contact us and we will then follow our Internal Dispute Resolution process. Please refer to the Contact details in the next section.

    Commercial Distribution Finance Pty Ltd ABN 54 608 590 727 and GE SPA Leasing Pty ABN 75 095 668 036 are not members of an External Dispute Resolution.

    You may also refer the matter to the Office of the Australian Information Commissioner (the "OAIC"). The contact details for the OAIC are:

    The Office of the Australian Information Commissioner
    GPO Box 2999
    Canberra ACT 2601
    Australia
    Phone: 1300 363 992
    Fax: 02 9284 9666
    Website: www.oaic.gov.au

  12. Contact details
    For Commercial Distribution Finance products, phone 1800 133 580, or contact your Relationship Manager.

The GE Companies covered by this policy are:

  • Commercial Distribution Finance Pty Ltd ABN 54 608 590 727
  • GE SPA Leasing Pty ABN 75 095 668 036

This policy may apply to other entities in the GE group who are credit providers, or who receive credit eligibility information under the Privacy Act from time to time.

Privacy Policy

Effective from 3 May 2016

The GE Companies* ("we" / "us"/ "our") take our obligations to protect personal information seriously. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs") (together, "the Privacy Act").

About this Privacy Policy

The purpose of this Privacy Policy is to tell you how we manage your personal information. This includes:

  • the kinds of personal information that we collect and hold about you;
  • how we collect your personal information;
  • how we hold your personal information;
  • the purposes for collecting, holding, using and disclosing your personal information;
  • how you may access your personal information held by us and correct that information where it is incorrect;
  • how you may make a complaint about the way we collect, hold, use or disclose personal information, and how we will deal with Privacy related complaints;
  • whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located.

You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account or relates to your personal information we will need to identify you before we can engage in further discussions and correspondence.

This Policy will be kept up to date and published on the Australian GE Capital websites.

The kinds of personal information we collect and hold about you

As a group of companies offering a wide range of products and services, we collect and hold personal information about you. We collect information from our customers, prospective customers, prospective employees, contractors, suppliers, brokers, introducers, merchants, agents, service providers and the people who represent the businesses we deal with.

The type of personal information we collect and hold may vary depending on the nature of our interactions with you. For example, our businesses that provide credit would collect and hold financial information, credit related information (please also refer to our Credit Reporting Policy), identification information, transaction / repayment history information, banking details and employment information. Our insurance business collects and holds identification information, financial information and health information, particularly in relation to insurance claims.

All of our businesses will collect and hold name and contact information of any individuals they deal with.

In order to satisfy our legal obligations, we may need to retain your information after a transaction or a relationship has ended. However, we will not retain your identifiable personal information longer than is reasonably necessary and permitted under Australian law.

Some elements of personal information are also referred to as sensitive information, these include:

  • racial or ethnic origin;
  • political opinions;
  • membership of a political association;
  • religious beliefs or affiliations;
  • philosophical beliefs;
  • membership of a professional or trade association or union membership;
  • sexual orientation or practices;
  • criminal history;
  • health information;
  • genetic information;
  • biometric information; or
  • biometric templates.

We will only collect sensitive information with your consent or when permissible under Australian law and will only use this information for a legitimate purpose where this is reasonably necessary.

How we collect your personal information

Wherever it is possible and practical to do so, we will collect personal information directly from you, this may be in person, over the telephone, by mail, over the internet, by e-mail or fax, or by completion of a form (such as an application form).

We may also collect your personal information from a third party. This will be limited to circumstances where it is impracticable or unreasonable for us to collect it directly from you. The type of third party who might provide information to us will vary depending on the nature of the business and interaction with you.

For our businesses which provide credit, third parties could be:

  • a credit reporting body (please refer to our Credit Reporting Policy for more details on how we handle credit reporting information);
  • an authorised representative (e.g. brokers, agents, accountants or solicitors);
  • a referee;
  • an employer;
  • a government body; or
  • another financial institution.

Whilst this is not an exhaustive list, all businesses may obtain your personal information from other third parties which could be:

  • someone authorised to act on your behalf (e.g. financial adviser, executor, administrator, trustee, guardian, attorney, accountant or consumer advocate);
  • recruitment consultants (e.g. for job applicants);
  • an introducer such as a broker, agent, dealer and retail partners;
  • third party service providers and / or suppliers; or
  • one or more of our related companies, in Australia or overseas.

How we hold your personal information

We understand the importance of protecting the personal information we hold about you. We take steps to ensure your personal information is free from misuse, interference, loss, unauthorised access or modification by:

  • securing all personal information;
  • limiting access to personal information only to those that need access; and
  • protecting our systems with appropriate technology solutions.

The purposes for collecting, holding, using and disclosing your personal information

We collect, hold, use and disclose your personal information in order to manage and administer the products and / or services we provide to our customers, whether they are individuals or businesses. You may be a customer, contractor, job applicant, supplier, partner or party with whom we do or have done business, or may do business with in the future.

As a financial services provider a major purpose for which we hold, use or disclose personal information is to assess credit applications, manage credit and insurance agreements, for planning, product and service development, research purposes and to analyse the risk profiles of our customers or potential customers.

Online servicing or access

When you register to access products or services online, the information collected is compared with the details we may already have stored, this might include your name and date of birth. This allows us to verify who is seeking access. If this information is not provided, you will not be able to access your personal information online.

Direct Marketing

Personal information may also be used or disclosed to advise you of products and services that may be of interest to you by means of direct marketing.

If you do not want your personal information to be used for direct marketing purposes please contact us so that we can action this request. This is referred to as "opting out" of direct marketing. You can "opt-out" of direct marketing by contacting GE on 1800 133 580.

How you may access your personal information held by us and correct that information where it is incorrect

You are entitled to access the information we hold about you. Simple requests are best handled by speaking to the relevant customer service area. More complex requests may be better detailed in writing to ensure we fully understand and are able to respond accurately to your request. You can contact us on 1800 133 580 or in writing at Attn: Commercial Operations Compliance, GPO Box 5321, Sydney, NSW 2000.

If there is a reason we are unable to agree to a request for access to your personal information we will advise you of this in writing. Some examples of why we may refuse a request for access include, where providing the information:

  • may pose a threat to the health or safety of an individual or the public;
  • may have an unreasonable impact on the privacy of another individual;
  • is not allowed by law; or
  • may reveal internal information relating to a commercially sensitive decision making process.

If information we hold about you is incorrect we would like to know so that we can promptly correct this. You can contact us on 1800 133 580 or in writing at Attn: Commercial Operations Compliance, GPO Box 5321, Sydney, NSW 2000.

In certain situations, we may not agree to a request to correct information we hold about you, if this occurs we will advise you of this and our reason for not agreeing to the correction request.

How you may make a complaint about the way we collect, hold, use or disclose personal information and how we will deal with Privacy related complaints

If you want to make a complaint about our handling of personal information we ask that you contact us first. We will then follow our Internal Dispute Resolution (IDR) process. You can contact us on 1800 133 580 or in writing at Attn: Commercial Operations Compliance, GPO Box 5321, Sydney, NSW 2000.

If the complaint remains unresolved you may refer the matter to the Office of the Australian Information Commissioner (the "OAIC"). The contact details for the OAIC are:

The Office of the Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601
Australia
Phone: 1300 363 992
Fax: 02 9284 9666
Website: www.oaic.gov.au

Who we may disclose personal information to

In order for the GE Companies to best provide our products and services to our customers, from time to time, we share personal information with our related bodies corporate, as defined in the Corporations Act 2001 (Cth).

We may also disclose personal information to non-GE businesses who provide various services to us. We require all of these businesses and our suppliers to comply with strict confidentiality requirements and the APPs. If you are our customer (or a representative of a customer) there is additional information about our disclosure of customer specific personal information in the product Privacy Notice.

When we may disclose personal information to overseas recipients and the countries where such recipients may be located

As is the case throughout the Australian financial services industry (and other major industries), technology allows for services to be provided by different service providers including some that are located overseas. We utilise overseas service providers for some of our activities and to do so may need to disclose personal information to those service providers. We may also disclose such information to other overseas recipients for the purposes listed above when permitted to do so by the Privacy Act.

Whilst it is not practicable to list every country in which such recipients are likely to be located, it is likely that the countries to which your personal information may be disclosed include China, Hungary, India, Japan, Mexico, New Zealand, Philippines, Poland, Singapore, South Korea, Spain, United Kingdom and the United States of America.

Tracking information on the web

For statistical purposes, we collect information on website activity such as the number of users who visit our websites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering one of our websites from another website, the address of that website. This information is obtained through the use of 'cookies' (refer below for more information about 'cookies').

Our websites may also contain links to non-GE websites. While these links are provided for convenience, if you are navigating these sites please be aware that the information handling practices of the linked websites may differ from ours. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other websites.

Website security

Whenever personal information is sent via our website we use high security levels to protect it. These security levels are standard for internet banking and large scale e-commerce sites and involve the use of 128-bit encryption. The security level of a web page can be viewed by clicking on the internet browser's padlock or key icon.

Cookies

A 'cookie' is a packet of information that allows a website to identify and interact more effectively with a computer. Cookies do not identify you, but they do identify your browser type and Internet Service Provider.

Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. If cookies are rejected, there may be limits on how our websites can be used. To evaluate the effectiveness of our website advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.

Website advertisements

From time to time we place GE advertisements on non-GE websites. This may involve installing a cookie on a computer when our advertisement is viewed. This simply allows us to keep track of how many unique visitors we have to our site and from what advertisements they entered. This then allows us to measure the effectiveness of different advertisements. The privacy policies of the websites which install the cookies should provide additional information about the use of cookies.

It is important to remember that a browser can be set to reject cookies.

*The GE Companies in Australia include:

  • GE Capital Asset Services & Trading Asia Pacific Pty Ltd ABN 20 078 961 118
  • Rohenryn Pty Ltd ABN 88 096 876 247
  • Commercial Distribution Finance Pty Ltd ABN 54 608 590 727
  • GE SPA Leasing Pty ABN 75 095 668 036

One or more of the Commercial Finance entities may act as an agent ("Agent"). You can enquire as to the identity of the principal by contacting the Commercial Operations Compliance area as detailed in the Important Privacy Notice given to you by the Agent or your Relationship Manager.