HomeStart Finance ("HomeStart") is committed to protecting the privacy of your personal information. This Policy explains how HomeStart manages personal information that it collects, holds, uses and discloses to ensure that your personal information and privacy are protected.
HomeStart loans are available through its network of Loan Consultants (see Section 10 below). HomeStart requires that the Consultants adhere to this Policy in respect of their dealings related to HomeStart products and services.
HomeStart complies with the Australian Privacy Principles (APPs), the credit provider provisions in the Privacy Act 1988, the registered Credit Reporting Code, and the South Australian Government’s Information Privacy Principles.
"Personal information" is essentially information or an opinion about you as an identified or reasonably identifiable individual.
This Policy is intended to cover most of the ways that personal information is generally handled by HomeStart, but is not exhaustive. If you have any queries about HomeStart's management of your personal information, please contact HomeStart's Privacy Officer for further information.
1. Collection of Personal Information
When collecting your personal information, HomeStart takes reasonable steps to make you aware of the purposes for which the information is being collected, the organisations to which HomeStart will usually disclose your information (and, if they are located overseas, the countries they are located in), legal obligations (if any) requiring HomeStart to collect the information, and the main consequences (if any) if you fail to provide any information that is requested.
HomeStart limits the personal information collected to that which is reasonably necessary for HomeStart's functions or activities. When reasonable and practicable, HomeStart only collects your personal information directly from you (often through its Loan Consultants). If you do not provide the personal information requested, we may be unable to assist you (for example, we may not be able to approve any application you make for a HomeStart loan).
HomeStart may collect personal information from you in a number of circumstances, including if:
- you apply for a HomeStart loan;
- you respond to HomeStart's marketing activities (such as surveys, email campaigns or polls);
- you contact HomeStart, for example, to enquire about HomeStart's products or services;
- you apply for employment with HomeStart.
The types of personal information that HomeStart collects and holds may include your name, email address, residential and/or postal address, telephone number, date of birth and/or employment history. We may also collect and hold identity verification documents which may include a copy of your driver’s licence or birth certificate.
HomeStart may also collect and hold other personal information, such as credit information or credit eligibility information obtained from a credit reporting body, in connection with your loan application or the ongoing management of your HomeStart loan/s. For more information on how HomeStart manages credit information please see HomeStart’s Credit Reporting Policy.
This information may be collected from you via our website, over the telephone, via email or mail, or in person and may be held in electronic or paper form.
HomeStart collects and holds personal information in order to conduct its business, to provide its products and services and to meet legislative and regulatory requirements. This generally involves, but is not limited to, collecting and holding personal information to:
- provide further information about HomeStart’s products;
- assess an applicant’s eligibility for a HomeStart loan;
- assess an applicant’s eligibility for a job vacancy;
- administer customers’ loans;
- resolve a complaint;
- conduct surveys;
- run competitions;
- undertake research.
As a state government agency, HomeStart must adhere to the requirements of the State Records Act 1997 (SA) with regard to the retention of records. Consequently, HomeStart will retain, or hold, personal information it collects in the conduct of its business, as required by the State Records Act.
Sometimes HomeStart may need to collect and hold sensitive information about you, which may include information about your racial or ethnic origin or your health. However, HomeStart will not collect sensitive information unless you have consented or we are otherwise permitted to collect this information under the APPs or by law.
2. Use of Personal Information
HomeStart will use personal information for various purposes, depending on the circumstances.
HomeStart will generally only use your personal information for the purpose for which it was collected, and for related purposes that are within your reasonable expectations. HomeStart will seek your consent prior to using or disclosing your personal information for another purpose, unless we are required or authorised by the APPs or by law to do so without seeking your consent.
If you apply for a HomeStart loan, HomeStart will use personal information from your loan application to determine your eligibility for a HomeStart loan.
Your personal information may also be used in market research studies to analyse products and customer needs and develop new products, although we will use de-identified information for these purposes when possible. If you respond to a survey or questionnaire, HomeStart will use that information to improve HomeStart's services or the products HomeStart offers to customers.
Your personal information may also be used to enable HomeStart to offer you other products or services that are related to products or services HomeStart has previously provided to you, and you consent to us doing so. However, if you do not wish to receive marketing or promotional communications from us, please notify HomeStart (using the contact details set out below), or use the opt out function provided for in those communications. Unless you opt out, you will be taken to have consented to receiving such communications. There are no consequences of opting out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to resubscribe to our marketing list at a later stage if you wish.
If you apply for employment with HomeStart, HomeStart will use personal information from your application to determine your suitability for employment.
If HomeStart collects sensitive information from you, that information will be used in a considerate manner by HomeStart and will be securely and privately stored.
3. Disclosure of Personal Information
HomeStart may disclose your personal information internally and to other organisations to enable it to provide and administer its products;
- HomeStart Loan Consultants, for purposes connected with the administration of your HomeStart loan;
- credit reporting agencies, for the purpose of obtaining your credit report (for more information see HomeStart’s Credit Reporting Policy at homestart.com.au/privacy);
- other credit providers, for the purpose of obtaining information from them about your credit history (for more information see HomeStart’s Credit Reporting Policy at homestart.com.au/privacy);
- your solicitor, conveyancer, real estate agent, builder, home insurer, valuer or financial adviser, for purposes connected with your home purchase;
- contractors or third party service providers (for example mail houses and archive companies), for purposes such as sending materials to you;
- electronic identification verification service providers;
- fraud prevention service providers;
- issuers of third party products with whom HomeStart has an alliance;
- other organisations, where you have provided your consent.
When HomeStart engages contractors and third party service providers to provide specialised services such as bulk mailing and market research services, these contractors and service providers are obliged to only use personal information disclosed to them by HomeStart for the specific purposes for which it was provided.
HomeStart will not sell your personal information to any third parties.
HomeStart uses external service providers to assist us in distributing emails to our customers. This involves disclosing your personal information to an administrator with data storage facilities in the USA. In these circumstances, we take steps to verify that your information will be handled appropriately and stored securely.
4. Access to Personal Information
You are entitled to obtain access to the personal information about you held by HomeStart, in accordance with the provisions of the Freedom of Information Act 1991 (SA) ("FOI Act"). HomeStart may deny your request for access if required or authorised to do so under any law (including the FOI Act). A request for access to your personal information must be sent in writing to HomeStart. HomeStart will respond to your request within 30 days of receiving the request.
You may request access your personal information held by HomeStart in writing. HomeStart will respond to your request within a reasonable period after your request is made. Please refer to Section 11 for contact details. APP 12 outlines your rights to access personal information in greater detail.
You may also be entitled to obtain access to your personal information held by HomeStart, in accordance with the provisions of the Freedom of Information Act 1991 (SA) ("FOI Act"). HomeStart may deny your request for access if required or authorised to do so under any law (including the FOI Act). If we do so, we will provide you with written reasons (unless it is unreasonable to do so) and the options available to complain about the refusal.
We may require you to pay a fee in order to access your personal information held by us. We will advise the amount of the fee payable (if any) once we have assessed your application for access. We will not charge a fee for you to lodge a request for access to or correction of your personal information.
If you lodge a request for access, we may provide you with access to your personal information in any of a number of ways (including, for example, supplying you with a copy or providing you with the opportunity to inspect it).
6. Storage of Personal Information
HomeStart takes reasonable steps to store your personal information securely, and has policies and procedures intended to ensure that your personal information is not misplaced or misused, and that unauthorised access to, or modification or disclosure of, your personal information does not occur.
7. Privacy Online
In this Policy below, "online services" refers to any services provided by HomeStart via the Internet (including email).
HomeStart may collect personal information from you if you submit this information to HomeStart via HomeStart's online services (for example, if you send HomeStart an email message or if you submit information to HomeStart using the website online enquiry form). We will use this personal information to contact you to respond to your message, and for other related purposes (for example, to provide you with further information if you request it).
7.1 Automatic Server Logs
When you visit HomeStart's web site, our web server collects the following information for statistical and customer service purposes:
- the numbers of users who have visited our web site;
- the demographic group information of users who have visited our web site, including age group, gender and interests;
- the date and time that users have visited the web site;
- the number of pages viewed and the documents downloaded;
- the type of browser software that you are using; and
- the type of operating system software that you currently use.
HomeStart makes no attempt to identify you or to track or monitor your browsing activities from the above information. We only use this information to improve the performance of HomeStart's web site and HomeStart's services to HomeStart's customers.
When indicated to you, HomeStart uses encryption and security technology (such as the Secure Sockets Layer ("SSL") standard, which encrypts information so that it cannot be viewed by another party as it is transmitted through the Internet) to protect any personal information you provide to HomeStart while it is in transit to or from HomeStart's web site. This may include information that is supplied in any surveys or responses to other marketing research methods.
You acknowledge that, if you provide any personal information to HomeStart via HomeStart's online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless HomeStart has indicated to you beforehand that a particular transmission of information will be protected (for example, by SSL, as outlined above).
7.3.2 HomeStart online
HomeStart's web site uses "session cookies" for existing customers who use the HomeStart online secure customer site.
Session cookies are used as a means of identification for the HomeStart online secure customer site to ensure that you are the authorised person to use the site, that your customer number and password details are correct, and so that we can provide your confidential information to you. These cookies are an integral part of the security process for using HomeStart's online services.
Upon closing your browser the session cookie set by the HomeStart online secure customer site will be destroyed and a new cookie will be created the next time you log in to the HomeStart online secure customer site. No information returned to HomeStart's server by the session cookie is used to track your browsing habits, and no other personal information is retained from your session.
7.4 Other Online Services
If any of HomeStart's online services (including any email messages we send to you) contain links to other online services that are not maintained by HomeStart ("Other Services"), or if Other Services link to HomeStart's online services, we are not responsible for the content of those Other Services or the privacy practices of the organisations that operate them, and by providing such links we do not endorse or approve the Other Services. This Policy applies only in respect of HomeStart's online services.
8. Dealing with us anonymously or using a pseudonym
You may deal with us anonymously or may use a pseudonym where it is lawful and practicable to do so. For example, when you are merely enquiring about our home loan products you do not have to provide your personal details and you may elect to receive information using an email address that does not contain your name.
HomeStart undertakes periodic reviews of its policies and procedures with guidance by HomeStart's legal advisers to ensure that the personal information held is managed by HomeStart appropriately. HomeStart therefore reserves the right to amend this Policy at any time. You may obtain a copy of the current version of this Policy by contacting HomeStart, or accessing HomeStart's web site.
If you have any queries regarding this Policy, or if you require further information about the ways we manage your personal information, please contact HomeStart's Privacy Officer.
If you wish to make a complaint, we encourage you to contact HomeStart's Privacy Officer to discuss your concerns.
Your complaint will be considered and dealt with by our Privacy Officer. Please refer to Section 11 for contact details.
If your complaint is considered to be of a serious nature, the Privacy Officer may escalate the complaint internally within HomeStart.
Please allow us a reasonable time to respond to your complaint. If you are not satisfied with our resolution, you may make a complaint to the Office of the Australian Privacy Commissioner whose contact details can be found at: www.oaic.gov.au/
11. Contact Information
Level 5, 169 Pirie St, Adelaide SA 5000
Ph: 1300 636 878
HomeStart collects your personal information (either directly or via our appointed Loan Consultants) so that we may provide you with our loan products and services. If you do not provide the information requested by HomeStart, we may be unable to assist you. For example, if you do not provide sufficient personal or financial information when you enquire about or apply for a HomeStart loan, we may not be able to proceed with your enquiry or loan application.
HomeStart may use your personal information for secondary, related purposes within customers' reasonable expectations, such as to provide you with information about HomeStart products or to conduct customer satisfaction surveys and research. You consent to HomeStart using your personal information for such purposes and for direct marketing, however you may tell HomeStart at any time that you do not wish to receive such information or otherwise participate (such as by using an opt out function provided in those communications).
In order to assess your eligibility for a loan, or for the ongoing management of your loan, HomeStart will usually disclose your personal information to its credit reporting provider (Equifax whose contact details can be found at: www.equifax.com.au/contact), other credit providers, valuers, solicitors, conveyancers, builders, mail houses, archive companies and our appointed Loan Consultants. The information disclosed will be strictly limited to what is required to provide HomeStart’s services or to comply with its legal and regulatory requirements.
HomeStart uses external service providers to assist us in distributing emails to our customers. This involves disclosing your personal information to an administrator with data storage facilities in the USA and Canada. In these circumstances, we take steps to verify that your information will be handled appropriately and stored securely.
- Access your personal information and credit eligibility information that is held by HomeStart;
- Seek correction of your personal information, credit information or credit eligibility information that is held by HomeStart; and
- Make a complaint and how we will deal with such a complaint.
Is English not your first language? HomeStart’s website can be translated into different languages. To use this tool, select the Languages link on the header (located at the top of any page of this website) and select your preferred language.
Please contact firstname.lastname@example.org if you have any queries or requests in relation to this Privacy Act.
HomeStart loans are available through its network of Loan Consultants. This Credit Reporting Policy also applies to HomeStart’s Loan Consultants in respect of their handling of credit data related to HomeStart products and services.
Generally speaking, credit data is information used to assess your eligibility to be provided with credit. It may include details of credit provided to you, repayment history information, and certain details regarding overdue payments or defaults.
This Credit Reporting Policy is intended to cover most of the ways that credit data is handled by HomeStart, but is not exhaustive. If you have any queries about HomeStart’s management of your credit data, please contact HomeStart for further information.
1. Collection of Credit DataThe kinds of credit data that HomeStart collects and holds may include:
- identification information (which may include your full name, previous name, alias, date of birth, gender, current and last known address and two previous addresses, the name of your current or last known employer, and driver’s licence number);
- a copy of documents that include such identification information (such as your driver’s licence, birth certificate or passport);
- consumer credit liability information (which may include information about existing credit provided to you such as the name of the credit provider, the type of credit, when it was provided, the terms and conditions that apply, the maximum amount of credit available, and the day on which the credit was terminated);
- repayment history information (which may include whether or not you have made a payment on time, when it was due and when it was paid);
- details of previous applications for credit made by you;
- default information (which relates to certain overdue payments);
- payment information (which relates to when such overdue payments were made);
- court proceedings information (which relates to court judgements about credit provided to you);
- personal insolvency information (for example, if you are declared bankrupt);
- publicly available information relating to your credit worthiness; and
- any opinion of a credit provider that you have committed a serious credit infringement.
- directly from you;
- from a credit reporting body (such as Equifax); and/or
- from other parties (for example, other credit providers) where permitted by the Privacy Act.
If you do not provide or agree to the collection of the credit data requested, we may be unable to assist you (for example, we may not be able to approve any application you make for a HomeStart loan).
HomeStart usually derives the following kinds of information from credit data disclosed to HomeStart by a credit reporting body (such as Equifax):
- internal assessments and calculations based on such credit data made by HomeStart in relation to your application for a HomeStart loan (intended to assess whether you meet HomeStart’s lending criteria);
2. PurposesHomeStart collects, holds, uses and discloses credit data in order to conduct its business, to provide its products and services and to meet legislative and regulatory requirements. This generally involves, but is not limited to, collecting, holding, using and disclosing credit data to:
- assess your eligibility for a HomeStart loan and credit worthiness. In particular, HomeStart will use your credit data to determine your eligibility for a HomeStart loan should you apply for one;
- administer customers’ loans; and
- resolve a complaint.
- credit reporting bodies (such as Equifax);
- other credit providers; and/or
- mortgage brokers and loan aggregators acting in connection with the introduction of your loan.
HomeStart will not sell your credit data to any third parties.
It is unlikely that HomeStart will disclose your credit data to overseas recipients.
3. Credit Reporting BodyPersonal information provided by us to Equifax may be included in reports provided by Equifax to other credit providers, to assist them to assess your credit worthiness.
If you fail to meet your payment obligations or commit a serious credit infringement, we may be entitled to disclose this information to Equifax. A serious credit infringement includes:
- fraudulently obtaining a loan;
- fraudulently evading (or attempting to evade) your obligations in relation to a loan; or
- an act that a reasonable person would consider indicates an intention to no longer comply with your obligations in relation to a loan.
- use credit reporting information about you for the purpose of pre-screening of direct marketing by a credit provider; or
- use or disclose credit reporting information about you if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.
5. CorrectionHomeStart takes reasonable steps to ensure that the credit data it collects, uses or discloses is accurate, up-to-date and complete.
If you believe any of your credit data held by HomeStart is incorrect or out-of-date you may make a written request to HomeStart or your Loan Manager (who will forward your request to HomeStart) seeking a correction. HomeStart will respond within a reasonable period after your request is made.
6. Storage of Credit DataHomeStart takes reasonable steps to store your credit data securely, and has policies and procedures intended to ensure that your credit data is not misplaced or misused, and that unauthorised access to, or modification or disclosure of, your credit data does not occur. Credit data may be held by us electronically or in hard copy form, and we employ security protections appropriate for the form in which that information is held (for example, passwords linked with authorised user access and physical document security).
7. AmendmentHomeStart undertakes periodic reviews of its policies and procedures with guidance by HomeStart’s legal advisers to ensure that credit data held is managed by HomeStart appropriately. HomeStart therefore reserves the right to amend this Credit Reporting Policy at any time. You may obtain a copy of the current version of this Credit Reporting Policy by contacting HomeStart's Privacy Officer, or accessing HomeStart’s web site.
If you have any queries regarding this Credit Reporting Policy, or if you require further information about the ways we manage your credit data, please contact HomeStart's Privacy Officer.
8. ComplaintsIf you wish to make a complaint in relation to your credit data we encourage you to contact HomeStart's Privacy Officer to discuss your concerns.
Your complaint will be considered and dealt with by our Privacy Officer. If your complaint is of a serious nature, the Privacy Officer may escalate your complaint internally within HomeStart.
Please allow us a reasonable time to respond to your compliant. If you are not satisfied with our resolution, you may make a complaint to the Office of the Australian Privacy Commissioner.
9. Contact InformationHomeStart Finance
Level 5, 169 Pirie Street
ADELAIDE SA 5000
Ph: 1300 636 878
Ph: 08 8203 4750