Privacy Policy - Border Bank

Last updated: February 2024

About us

Border Bank Limited (‘the Bank’) is a member owned bank that provides a range of banking and financial products and services. Police Bank and Bank of Heritage Isle are divisions of the Bank.

Our commitment

At Border Bank , we understand your privacy is important to you and are committed to keeping your personal information secure. We value your trust in us and will operate in accordance with Australian Privacy Laws (the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles (APPs), Privacy (Credit Reporting) Code (CR Code) and Customer Owned Banking Code of Practice (COBCOP).

This Policy sets out:

the kinds of personal information we collect
the reason why we collect and use your information
how we handle personal information, credit reports and other credit information about you; and
important information about credit reporting matters.

We will endeavor to tell you how we collect and use your information, for example, when you complete an application, make a claim, or receive our terms and conditions. We also have a Privacy Notice found here, which describes how we collect, use, hold and share your personal information.

This Privacy Policy applies in relation to all of our products and services provided to you and is hosted on our website and is also available on request and free of charge.

Information we collect

We collect information about you:

when providing our products and services to you, when you contact us, visit our website, use our apps or visit a retail branch.
from other people and organisations.

Personal Information that we collect from you

Personal information that we may collect from may include both sensitive information and credit information.

We will only collect and hold personal information that is related to our providing products and services to you, related to our business or potential employment relationship with you. Where it is practical to do so, we will collect your personal information directly from you. However, in certain circumstances we may also collect your personal information from third parties as explained below.

We may collect the following types of personal information from you:

Name, residential address, date of birth, gender and contact details
Identification information such as drivers licence, passport details or Medicare card number
Account transaction history or credit information that we can collect directly from you
Relationship information
Place of employment and previous employment details
Educational qualifications
References from referees that you nominate
Identifiers assigned to you by government authorities such as tax file number (TFN), Medicare card number, or Australian Business or Company Number ( ABN or ACN) and/or tax residency status
health information for hardship applications, insurance or other purposes
details about when and how you interact with us include telephone call recordings, emails or notes on our systems
financial position and transaction history and/or credit history
complaint related information
Your reasons for applying for a product or service
Publicly available information

Credit-related personal information that we may collect from you or third parties

Credit-related personal information includes the following:

Credit information is basic information collected about you when you apply for credit. Or a credit facility such as a loan that relates to your creditworthiness.

Credit information may include:

Identity details such as name, gender, date of birth, address and employment detail
information about your current or terminated consumer credit accounts and may include date of opening of account, type of credit, credit limit, repayment terms and date account is closed
information about consumer credit payments overdue for at least 60 days and for which collection activity had commenced;
Details of payments which are overdue by more than 60 days and where collection action has commenced ( or that these repayments are no longer overdue)
Information about credit arrangements made with a credit provider to deal with any defaults and serious credit infringements
Credit provided to you has been paid or discharged
Repayment history information (RHI)

Credit reporting information which we may collect from you or third parties

Credit reporting information includes any credit information held by a credit reporting body about you and any further information that the credit reporting body obtains from that information that affects your creditworthiness and that can be used to assess your eligibility for credit.

Credit reporting information may include:

credit information provided to the credit reporting body by another credit provider
information about court judgements which relate to credit being obtained or applied for
information about you on the National Personal Insolvency Index;
publically available information about your credit worthiness; and/or
the opinion, rating or other information provided by the credit reporting body in relation to your credit worthiness ( for example a credit score).
Credit eligibility information includes any information that has been obtained from a credit reporting body and/ or that the bank has been derived from that information that affects your credit worthiness and can be used to establish your eligibility for credit. This may include any analysis and assessments made by the Bank when assessing a credit or loan application.

Sensitive Information

The Privacy Act protects sensitive information about you such as your biometrics (fingerprints), sexual orientation, criminal record, ethnicity, health religion and political opinions.

We will not collect your sensitive personal information unless it is necessary to provide you with the product or services you have requested. We will seek your permission and consent to collect and use this information where we are not allowed to do so by law.

Information we collect from third parties

We may also collect information about you from others such as:

Employers (for example as referees)
service providers
credit reporting bodies
companies that you have shares or have invested in
brokers, agents or advisers
publicly available information

Accessing our website and Cookies

When you use our website, internet banking or mobile banking apps our servers we generally use Cookies that tell us information such as your IP address, location, mobile device and network information and third party websites that you visit.
We use this information to help us improve and tailor our product and service offerings to you. If we do identify you using cookies we will only use the information we collect in accordance with this Privacy Policy, Australian Privacy Laws and Regulations and Australian Privacy Principles.
If you do not wish to receive cookies, you can set your browser to refuse them. However if you refuse them you may not be able to access certain parts or features and services available on our website.
We are not responsible for the content or material that you access on third party websites.

How we use your information

We collect, use and share your information to:

verify your identity in line with applicable Australian laws and regulations
assess your eligibility to become a member
assess your application for a product or a service, including applications for credit or proposal for you to provide a guarantee or other credit to support us
manage our relationship with you and help provide a better customer experience
process payment requests
design, and price our member benefits, services and products
minimise risks, identify or investigate fraud and other illegal activities
comply with our legal obligations and assist government and law enforcement agencies
recover any amounts owing by you to us
assess your employment application with us
any other purpose that you may approve from time to time
inform you about products and services that may be of interest to you and for marketing purposes
We also use your information to help us better understand your needs and circumstances, so we can offer, provide and deliver products and services that we think may be of interest to you or for the purposes of potential employment relationship with you.

You can opt out of receiving direct marketing material at any time:

online at Border Bank | Marketing Opt Out
by calling our Contact Centre on 132 267
visit one of our retail branches.

Even if you opt out of receiving direct marketing material, we will still send you essential information, particularly information that we are legally required to send you relating to the products and services we provide to you.

Who we disclose your information to

We share your information with other entities such as:

entities that verify your identity
clearing, payment and credit card scheme providers
security providers that minimise risks and block suspicious behaviour
lawyers, conveyancers, accountants, brokers, advisers and agents that represent you
suppliers that assist with administrative functions (among others) such as printing and mailing out statements, card and cheque production, market research or direct marketing
service providers such as mortgage insurers, affiliated product and service suppliers, product providers, and product distributors
credit reporting bodies and credit providers
property valuers and insurers
investigators, debt collection agencies and process servers
our auditors or insurers
other banks and financial institutions, for example, if we need to process a claim for mistaken or misdirected payment
people that transact on your account such as a family member, guardian, trustee or Power of Attorney
security providers such as guarantors
law enforcement, regulatory bodies and government agencies as required by law.

Credit reports

Border Bank is part of the Australian credit reporting system. When you apply for credit (or to be a guarantor for someone else’s credit contract) we may request your credit reports from a credit reporting body. Credit reports show the history of the credit activities that you have engaged in, and credit score which allow credit providers such as Border Bank to assess your credit worthiness.

We share the following information with the credit body so we can receive your credit report:

your identity
the amount of credit that you have applied for
the amount and type of credit that you have
your repayment history
collection of overdue payments from you
whether you have committed fraud, a serious credit infringement or have made the same application for credit with another credit provider.

The credit reporting body that Border Bank works with, discloses information to and exchanges information with is Equifax Australia Information Services and Solutions Pty Ltd (Equifax):

Equifax

Website: www.equifax.com.au

Phone: 138 332

You can access Equifax’s privacy policy at: Equifax Australia Information Services and Solutions Pty Limited

We may also exchange personal information, your credit history or information in your credit report with other credit providers in assessing your credit worthiness. This includes notifying other credit providers of any defaults by you.

You can access your credit information and request a correction to it by the relevant credit reporting body or make a complaint to us using the details provided below.

The government has legislated a mandatory CCR regime which the Bank will follow. CCR is a credit reporting system where credit providers such as Border Bank are required to share your credit history, with both negative and positive credit data about you with credit reporting bodies.

CCR means that credit reports will represent a more holistic picture of your credit history that will allow the Bank to make more informed assessments of your ability to repay the loan, and make better decisions about the products and services that benefit you. You can request a free copy of your credit report from any credit reporting body once a year or contact Credit Smart to obtain a copy. You can contact Border Bank on the details provided below if you are having trouble making your repayments on time.

Comprehensive credit reporting (CCR)

The government has legislated mandatory CCR regime which the Bank will follow. CCR is a credit reporting system where credit providers such as Border Bank are required to share your credit history regarding both negative and positive credit data about you with credit reporting bodies.

CCR will mean that credit reports will represent a more holistic picture of your credit history that will allow the Bank to make more informed assessments of your ability to repay the loan, and make better decisions about the products and services that benefit you. You can request a free copy of your credit report from any credit reporting body once a year or contact Credit Smart to obtain a copy. You can contact Border Bank on the details provided below if you are having trouble making your repayments on time.

How we protect your information

We store your information in our systems as well as trusted third party systems such as cloud-based servers. We have security systems and protocols in place to prevent unauthorised access, modification or disclosure of information.

Our staff are trained to handle and keep your information safe and secure in accordance with Privacy Laws. We also limit access to our employees on a needs basis. We destroy or de-identify information that we no longer need where permitted by law. Although we will take reasonable practical measures to guard against interferenc

We store your information in our systems and databases as well as trusted third party systems such as cloud-based servers. We have security systems and protocols in place to prevent unauthorised access use, modification or disclosure of your information.

Our staff are trained to handle and keep your information safe and secure in accordance with Privacy Laws. We also limit access to our employees on a needs basis. We destroy or de-identify information that we no longer need where permitted by law. Although we take reasonable practical measures to guard against interference, we cannot guarantee the security of personal information that is transmitted over the internet.

Disclosure to overseas recipients

We may disclose your information to third parties that are based overseas such as Western Union or international banks when processing cross border transactions or telegraphic transfers to other countries. As a credit provider, Border Bank is restricted from disclosing credit eligibility information to overseas recipients that do not have an Australian link.

Data breach notification

We are required to notify you and the Office of the Australian Information Commission (Privacy Commissioner) of Notifiable Data Breaches that may likely result in serious harm to you, and recommend steps you can take to limit the impacts of the breach such as changing your password, account number etc. You can also contact us where you believe your personal information has been impacted by a data breach.

Accessing your personal information or Consumer Data Right (CDR) data records

You can request access to detailed personal and account information that we hold on record, at any time by contacting us on details provided below. We may charge you a document retrieval or related fee applicable to cover the reasonable costs of retrieving and making copies of your personal information, which we will disclose to you on request.

We will respond to requests for access to your personal information within 30 calendar days. The 30 day time period commences on the day after the day that we receive your request. We will either give you access to the personal information that you have requested, or we will notify you of our refusal to provide access, for example in cases where the provision of such information would interfere with another person’s privacy. If it is impracticable for us to respond within this 30 day timeframe, we will contact you to explain the delay and provide you with an expected timeframe for finalising the request.

We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate and current. However, if the information we hold on file about you is incorrect, incomplete or not current you can request that we correct it. If we have given the information to a third party, we can notify them of the correction. Where the information has been given to us by a credit reporting body or third party, we may need to contact the provider and request a correction. We will notify you in writing within 30 days whether the correction has been made, and will provide reasons where we are not able to so.

We are here to help you

To access your personal information, request a correction or make a complaint, you can:

call us on 132 267
email us on info@borderbank.com.au
visit one of our retail branches
write to us to 25 Pelican Street, Surry Hills, NSW 2010.
visit complaints and feedback
inform us if you have a concern or complaint about your privacy, credit report, or products or services that we have provided you. We will endeavour to have your concern or complaint attended to and resolved amicably within prescribed timelines.

If you are not satisfied with our handling of your complaint, you can make a complaint, free of charge, to either the:

Privacy Commissioner Phone: 1300 363 992 Website: http://www.oaic.gov.au/privacy/privacy-complaints. Mail: GPO Box 5218, Sydney NSW 2001, or

Australian Financial Complaints Authority (AFCA) Phone:1800 931 678 Website: www.afca.org.au Email: info@afca.org.au Mail: Australian Financial Complaints Authority GPO Box3, Melbourne VIC 3001

You can access our Privacy Notice here.