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Privacy and the Information Handling Practices of the Citiwide Group
How We Handle Your Personal Information
Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details, as well as your financial information. We are part of the Citiwide Group. We will act to protect your personal information in accordance with the National Privacy Principles or an industry privacy code.
The Group is a collection of related organizations that provide mortgage broking, insurance, conveyancing, financial planning and advice and finance services. We value your trust, and aim to help you manage and build wealth over a long period. The protection of your personal information is a vital part of this relationship. It is supported by our long experience of keeping personal information confidential.
We collect personal information to provide you with the products and services you request as well as information on other products and services offered by us. The law may also require us to collect personal information. We will tell you who collects the personal information, advise you of their contact details, your right of access to that information, and what will happen if you choose not to provide the information.
Personal information may be used and disclosed within the Group to administer our products and services and unless you tell us otherwise, to provide you with related marketing information. We co-operate with police and other enforcement bodies as required or allowed by law.
We disclose relevant personal information to external organizations that help us provide services. These organizations are bound by confidentiality arrangements.
You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why. For example, we may give an explanation of a commercially-sensitive decision, rather than direct access to evaluative information connected with it.
Some of the recipients to whom we disclose your personal information may be based overseas, including India and the Philippines. APP 8.1 shall not apply to the disclosure, meaning that we will not be obliged under the Privacy Act to ensure that an overseas recipient does not breach the APP. In addition, if that overseas recipient handles the information in breach of the APP, we will not be accountable for that breach and you will not be able to seek redress under the Privacy Act.
In addition, we may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held.
Further information and feedback
The pages that follow contain more detailed information about our privacy and information handling practices. If you have any questions or would like further information on our privacy and information handling practices, please contact us by:
e-mail to: firstname.lastname@example.org
telephone: 1300 732 630, or writing to the address below:
PO Box 263
Flinders Lane Vic 8009
e-mail at: email@example.com
Telephone: 1300 732 630
What You Need To Know And Where To Find It
Common law duty of confidentiality
As part of the general law governing the broker/customer contract, brokers have always been required to keep any information about their customers in the strictest confidence. Brokers have only ever been able to disclose information they hold about a customer if they have the customer’s consent, the disclosure is compelled by law (such as under the Tax Acts), is in the public interest, or is required in the best interests of the Broker (such as when a dispute goes before a court).
As a matter of policy, all members of the Citiwide Group observe this standard of confidentiality (even if they are not brokers) although under the Privacy Act, members of the Citiwide Group are entitled to (and do) disclose personal information to each other.
Privacy Act 1988
The Commonwealth Government has enacted privacy legislation to protect information held by all credit providers (not just brokers) about their customers’ personal credit dealings. Since 1991, under Part IIIA of the Privacy Act, credit providers (that indirectly includes Citiwide) have only been allowed to disclose information about personal credit dealings to certain classes of persons (such as a bank or a building society) for certain very limited purposes.
Privacy Amendment (Private Sector) Act 2000
In December 2000, the Commonwealth Government enacted further privacy legislation, to commence 21 December 2001, amending the Privacy Act (implementing the National Privacy Principles) to include provisions that regulate the way private sector organizations collect, use, disclose, keep secure and provide access to personal information.
Citiwide (the Group) acts to protect your personal information in accordance with the National Privacy Principles or an industry privacy code.
The information in this document details how we comply with the requirements of the Privacy Act in protecting the personal information we hold about you.
Collection of Personal Information
What is “personal information”?
Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Why we collect information
Personal information is collected so that we may;
- Administer our customer relationships and supply to our lenders the information necessary to process and approve our customers’ loan application
- Provide customers with the products and services they request and, unless they tell us otherwise, to provide information on products offered by the collecting member and other members of the Citiwide Group.
Personal information may also be used for;
- monitoring and evaluating products and services;
- gathering and aggregating information for statistical, prudential, actuarial and research purposes;
- assisting customers with queries; and
- taking measures to detect and prevent frauds and credit loss.
What we collect
Personal information collected by members of the Citiwide Group generally comprises name, address, date of birth, gender, occupation, account details, contact details (including phone, fax and e-mail) and financial information. Sometimes we collect a few personal details unlikely to be known to other people to help us identify you over the telephone.
If you are applying for credit we may also collect your employer’s name and contact details, the length of your employment, proof of earnings and, if you have changed employer in the last few years, details of your previous employment. We use this information to assist in making responsible credit decisions. In addition, as required by Part IIIA of the Privacy Act 1988, we will obtain your consent to collect, use and disclose credit information about you.
If you have or are applying for life insurance or income protection insurance, we also collect medical and lifestyle information that relates to the insurance. This information may include your sexual activity and is collected so we may assess whether to accept your insurance proposal and, if so, on what terms.
We are required by law to identify you if you are applying for a mortgage, opening a new bank account, establishing a new facility or adding a new borrower to an existing loan account. The Financial Transaction Reports Act 1988 requires us to sight and record details of certain documents (for example, birth certificate, passport) in order to achieve 100 points of identification.
Where it is necessary to do so, we also collect information on individuals such as company directors and officers (where the company is our customer) as well as customers’ agents and persons dealing with us on a ‘one-off’ basis.
We do not collect information about your political or religious beliefs, or ethnic background.
What if you provide incomplete or inaccurate information?
We may not be able to provide you with the products or services you are seeking.
Obtaining your consent
In most cases, before or at the time of taking out a new loan from a member of the Citiwide Group (or, if that is not practicable, as soon as practicable thereafter) the collecting member obtains your consent to the purposes for which it intends to use and disclose your personal information. If you do not give us consent, we may not be able to provide you with the products or services you want.
Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact the member of the Citiwide Group from whom consent is to be withdrawn. Please note that withdrawing your consent may lead to the Group member no longer being able to provide you with the product or service you enjoy.
Information collected from someone else
In some cases, your personal information may be provided to us by real estate agents, your accountant or by family members or friends. We will take reasonable steps to let you know that we have your personal information, unless it is obvious from the circumstances that you know or would expect us to have the information, such as where an accountant or solicitor or another broker is acting on your behalf. Reasonable steps may include asking the person who gave us your information to let you know that we have that information.
Other Members of the Citiwide Group
Members of the Citiwide Group that have collected personal information are permitted by the Privacy Act to disclose personal information to other members of the Citiwide Group. This enables the Group to have an integrated view of its customers. Any such disclosure is controlled by the Privacy Act. Without your consent, other members of the Group may not use or disclose your personal information for purposes other than for which your information was originally collected. All members of the Group observe the same standard of privacy and information handling practices.
Who we may communicate with
Depending on the product or service you have, we may exchange personal information with:
- real estate agents or accountants who refer business to us;
- valuers and insurers if you are borrowing through us to purchase property;
- lending institutions such as banks and building societies and mortgage managers for whom we act as business introducers or agent;
credit reporting agencies;
- insurers, including proposed insurers and insurance reference agencies;
- solicitors or conveyancing agents we instruct to act on your behalf;
- medical practitioners;
- other financial institutions and organizations at their request if you seek credit from them;
- suppliers from whom we order goods on your behalf;
- other organizations who in conjunction with us provide products and services; and
- professional associations or organizations with whom we conduct an affinity relationship.
We disclose personal information when we outsource certain functions, including bulk mailing, market research, debt recovery and information technology support. We also seek expert help from time to time to help us improve our systems, products and services.
In all circumstances where personal information may become known to contractors or agents, there are confidentiality arrangements in place. Contractors and agents are not able to use or disclose personal information for any purposes other than our own.
The Citiwide Group takes its obligations to protect customer information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.
Exchanging information with a credit reporting agency
When you apply for credit we need to be in a position to decide whether or not you are likely to repay. Our decision will be based on your current financial position (including your other credit repayments) and on your credit history (whether in the past you have been a reliable re-payer). We will consider the information you give us when you fill out your application and may check that information with a credit reporting agency and with any other credit provider with whom you have had dealings.
In checking with a credit reporting agency, we are looking to confirm the completeness and accuracy of information you have provided on your application form. This helps you as well as us because we do not want to give you further credit if, given your existing borrowings, you will have difficulty making repayments.
Where the Privacy Act applies we can only give information about you to a credit reporting agency if we first have told you that we will do so, and we can only obtain information about you from a credit reporting agency if we have your consent.
You may obtain a copy of credit reports about you. Please refer to the Access to personal information section for details of how to do this.
Disclosure required by law
We may be required by law to disclose information, for example, when we are served with a court order. We may also be required by a Government Agency to produce information and records, for example, pursuant to taxation or social security laws.
Disclosure as a result of your actions
There may be circumstances in which we consider you, by your actions, to have released us from our duty of confidentiality or to have consented to the disclosure of information about you without actually saying so (for example, if you discuss your financial position publicly to the media, in such a way as to leave us with little alternative but to respond publicly.
Personal Information Quality
Our goal is to ensure that the personal information we hold is accurate, complete and up-to-date. Please contact us if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up-to-date.
Personal Information Security
We are committed to keeping secure the personal information you provide to us. We take all reasonable precautions to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.
We have a range of physical and technology policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
Our security measures include, but are not limited to:
- restricting access to our computer systems and physical records to authorised persons and preventing users from accessing information they have no need to access;
- requiring employees to use unique passwords to gain access to systems. These passwords are changed regularly and their use is independently monitored;
- encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
- employing firewalls, intrusion detection systems and virus scanning tools to prevent unauthorised persons and viruses from entering our systems;
- using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
- practising a clean desk policy in all of the Groupâ€™s premises and providing secure storage for physical records; and
- detecting and preventing unauthorised access to buildings by employing physical and electronic means such as alarms, cameras and guards as required.
Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing (demagnetism of the medium using alternating electric currents) and other means in the case of electronic records and equipment.
Collection of information via web site activity
A cookie is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer.
When you use one of our web sites, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use one of our web sites. Cookies do not identify individual users, although they do identify a user’s browser type and your Internet Service Provider (ISP).
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our web sites.
To evaluate the effectiveness of our web site advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.
Links to other websites
Our web sites may contain links to non-Citiwide Group web sites. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours.
We may monitor and record telephone calls for training and security purposes.
One of the reasons we collect personal information is so that we may provide you with information on products offered by or through the collecting member and other members of the Citiwide Group. However, you may, if you wish, indicate that you do not want to receive information on products offered by or through the collecting member by ‘ticking the box’ on the form you sign when you take out a product or service; or contacting the collecting member at any time to indicate that you wish to ‘opt out’ of receiving such information.
Please note that if you provide your information to more than one member of the Citiwide Group, you will need to tell each member if you wish to ‘opt out’ of receiving information from them.
Changes to our Privacy and Information Handling Practices
The Citiwide Group may make changes to its privacy and information handling practices from time to time for any reason. We will publish those changes on our web sites and, if there are important changes or a lot of minor changes, by updating this document. This document is dated 20 December 2001.
Access to personal information
You can request us to provide you with access to the personal information we hold about you.
Requests may be denied or limited
If particular circumstances apply, we are permitted by the Privacy Act to deny your request for access, or limit the access we provide. We will let you know why your request is denied or limited. For example, we may give an explanation of a commercially-sensitive decision, rather than direct access to evaluative information connected with it.
Jointly held information
Where we hold your personal information in conjunction with that of another individual or individuals (eg. where you jointly apply for a loan), we will allow each individual access to their own personal information and to the joint information (eg. loan details and transaction details) but not to the personal information of the other individual(s).
Responding to an access request
We will respond to your access request as soon as possible. We will endeavour to comply with your request within 14 days of its receipt but, if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days. It will help us provide access if you can tell us what you are looking for. Your identity will be confirmed (including by verifying your signature) before access is provided.
An access charge may apply
An access charge may apply, but not to the request itself. The charge is for the time we spend on locating, collating and explaining the information you request (generally based on a rate of $60 per hour or part thereof) plus any photocopying costs and out of pocket expenses (such as freight and travelling costs).
How to gain access
Please write a letter specifying details of your request, sign it and either mail it to Customer Relations, Citiwide Group, PO Box 189, North Melbourne VIC 3051, or hand it in at any Citiwide branch. Following receipt of your request, our Customer Relations area will provide you with an estimate of the access charge and confirm that you want to proceed. Unless you have authorised us to debit your credit card account, access will not be provided until payment is received.
Access to a credit report about you
You have the right to ask for a copy of any credit report we have obtained about you from a credit reporting agency. However, as we may not have retained a copy after we have used it in accordance with Part IIIA of the Privacy Act, the best means of obtaining an up-to-date copy is to get in touch with the credit reporting agency direct. You have a right to have any inaccuracies corrected or, if there is any dispute as to accuracy, to have a note added to your credit reporting agency file explaining your position.
If we or one of our lenders decline your credit application wholly or partly because of adverse information on your credit report, the Privacy Act requires us to tell you of that fact and how you can go about getting a copy of your credit report.
The major credit reporting agency in Australia is Credit Advantage Limited. As the largest agency, it is likely that it will be Credit Advantage Limited that you will need to contact in relation to access to an up-to-date copy of your credit report and any correction of information on your file. Credit Advantage Limited has established a specific public access division to handle these matters: Public Access Division, Credit Advantage Limited, PO Box 964, North Sydney NSW 2059.
Contact Us About Our Privacy and Information Handling Practices
If you have any questions or would like further information about our privacy and information handling practices, please contact us by:
e-mail at: firstname.lastname@example.org
telephone (03) 9326 6300, or writing to the address below:
Citiwide Mortgage Services
PO Box 189
North Melbourne VIC 3051
Making a privacy complaint
We recognise that even in the best run organizations things can go wrong. Should you have a privacy complaint, please tell us because it gives us the opportunity to fix the problem. We will investigate the complaint, answer your questions and do all we can to regain your confidence.
To assist us in helping you, we ask you to follow a simple three-step process:
Gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
Contact the relevant Group member, where your situation will be reviewed and if possible resolved straight away. A quick chat is all that’s required to resolve most issues.
If at this stage the matter has not been resolved to your satisfaction, please contact our Customer Relations team using the above contact points. Rest assured that an officer with the necessary authority will review your case. If you are still not satisfied, we will tell you about the dispute resolution avenues available to you.