Members Equity Bank Ltd and its subsidiary ME Portfolio Management Limited (referred to as ME, we us or our) has implemented this Privacy and Credit Reporting Policy to provide you with information about how we collect, hold and use the personal information and credit-related personal information that you provide to us.
We appreciate that the protection of your personal information, which has been provided in the course of business, is of the utmost importance to you and to us, as is the need to base our relationship on mutual trust. Our management and staff are aware of the need, and are trained, to exercise the utmost discretion in handling your personal information and credit-related personal information.
We will apply our privacy compliance procedures in relation to any personal information and credit-related personal information which we gather in the course of carrying on our business. These are based on privacy legislation including until 12 March 2014, the National Privacy Principles for the Fair Handling of Personal Information (NPPs), and after 12 March 2014 the Australian Privacy Principles (APPs). In addition, our procedures for handling credit-related personal information are based on the requirements for credit reporting set out in Part IIIA of the Privacy Act. We regard all the personal information we have collected from and about you as being equally sensitive and undertake to treat it all in accordance with the principles set out in this Privacy and Credit Reporting Policy.
1. contacting us
If you have any general privacy or credit reporting enquiries, access and correction requests and complaints please contact us:
A copy of this Privacy and Credit Reporting Policy is available at www.mebank.com.au or on request at the contact details set out above.
2. collection of Information
2.1 We only collect personal information which is relevant to and necessary for a legitimate function or activity of our business or for related purposes.
2.2 Personal Information
Personal information is information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable from the information or opinion.
2.3 The types of personal information that we collect may include (but is not limited to) the following:
2.4 In addition, where relevant for credit accounts we may also collect:
2.5 Sensitive information includes, for the purpose of carrying on our business, information or an opinion about an individual's:
2.6 With your consent, we may collect sensitive information about you, including details of trade union membership.
2.7 We may collect your personal or sensitive information when you:
2.8 We may also collect personal information about you via third parties (for example, from our alliance partner organisations). However, we will only collect your personal information in this way if it is unreasonable or impractical to collect this information directly from you or if we are otherwise permitted to do so. To the extent we consider it relevant to assessing your application for consumer or commercial credit, we may obtain a credit report from a credit reporting body that contains personal information.
2.9 Credit-related Personal Information
We may collect all types of credit information (including repayment history information), credit reporting information and credit eligibility information, being information relevant to our credit products as described below:
Credit information is the basic category of personal information in the credit reporting system. It includes the following types of information collected by us that we may give to a credit reporting body, such as Veda.
Credit information does not include sensitive information – eg criminal record, medical history.
Credit reporting information means credit information that a credit reporting body holds or personal information a credit reporting body derives from credit information it holds about an individual. This will be the information that we receive from a credit reporting body about a borrower, loan applicant or guarantor.
Credit eligibility information refers to the information disclosed by a credit reporting body to us; or the information derived by us from that credit reporting information (for example a credit score).
The terms credit information, credit reporting information and credit eligibility information are collectively referred to as credit-related personal information in this Policy.
2.10 We collect credit-related personal information if you apply for or have a credit product with us. We may use credit-related personal information to create a credit score for you. We also collect credit-related personal information from Veda Advantage Information Services and Solutions Limited (Veda) (see section 3.5 below)
2.11 We will:
3. use and disclosure
3.1 We may use your personal information for:
3.2 Where permitted by the Privacy Act and if we have your consent to do so (where consent is required), we may also seek and use your credit-related personal information from a credit reporting body:
3.3 We may, where permitted by the Privacy Act, disclose your personal information and credit-related personal information (including repayment history information) to the following organisations:
3.4 For home loan customers only, we may share your personal information and credit information with one of two mortgage insurers if mortgage insurance is required. Their contact details are as follows:
3.5 We may also disclose your personal information and credit information to Veda Advantage Information Services and Solutions Limited (Veda) or other credit reporting bodies as set out in this Privacy and Credit Reporting Policy from time to time. A copy of Veda's Credit Reporting Policy can be obtained by contacting Veda:
3.6 You should be aware that:
4. cross border disclosure of information
4.1 We will not send your personal information outside Australia unless we are satisfied that the overseas recipient of the information has adequate data protection arrangements in place, or you have consented to the transfer of the information.
4.2 We may disclose your personal information to our third party services providers for them to help us provide banking services to you. Our third party service providers may store or access your personal information overseas, including in Canada, USA, United Kingdom, Philippines, Singapore, New Zealand and Hong Kong.
5.1 We may use your personal information to keep you up to date with our products and services. If you do not want us to do this, please contact us. If we previously obtained your consent, we may disclose your personal information to an alliance partner with which we have arrangements. We may do this so that our alliance partners may contact you about other products or services that you may be interested in.
5.2 We may use information we receive about you from our alliance partners, such as insurers, to assist our staff in better identifying the products and services that may be relevant to you and for marketing and administrative purposes.
6. storage and data security
6.1 We aim to keep your personal information and credit-related personal information secure. This includes any information that is collected via our website or which is held in either hard copy files or electronically on our computer systems either on our premises or offsite with our trusted third party service providers.
6.2 We will:
Where we no longer require your personal information or credit-related personal information, we will take reasonable steps to destroy or permanently de-identify that information and to ensure that we are not able to use or disclose digital records of the information.
6.3 We have stringent procedures which require our staff and third party service providers to ensure the safe handling and storage of all private and confidential information including procedures for safe custody and transit of information both inside and outside ME, including the security of electronic submission and storage of credit-related personal information.
7. access and correction
7.1 You are entitled to access the personal information and credit-related personal information that we hold about you. We are committed to keeping up-to-date records of your personal information and credit-related personal information. You may request at any time that we grant you access to or correct your personal information or credit-related personal information by contacting our Privacy Officer (see Contact Us section).
7.2 We will:
7.3 We will:
8. if you have a privacy question, problem or complaint about our use of your information
8.1 If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy and Credit Reporting Policy, or for any other queries in relation to this Policy, please contact our Privacy Officer (see Contact Us section).
8.2 You should address any complaint in writing to ME in the first instance. We will investigate your queries and complaints. If your complaint relates to:
8.3 We are a member of the Financial Services Ombudsman (FOS). If you are not satisfied with the outcome of our investigation in relation to our handling of consumer credit-related personal information or an access or correction request you may take your complaint to FOS. A complaint relating to your personal information may ultimately be addressed to the Office of the Australian Information Commissioner.
9. ME's employee personal information
We also collect personal information about our current, past and prospective management, employees and contractors. The general personal information collected from these people includes:
It may also include sensitive personal information:
We may use the personal information of current, past or prospective management, board members, employees, job applicants and contractors for purposes such as recruiting employees, assisting employees to perform their duties and develop in their careers, managing salary and leave entitlements, managing workers compensation and occupational health and safety issues in the workplace, contacting employees at home where necessary and dealing with employment matters generally (including without limitation, matters arising out of the ending of an employment or contractual relationship and/or disputes).
In some instances, we may disclose our employee personal information to:
We may disclose information where required to by law or at the request of law enforcement agencies.
10. Visiting Our Website
You can browse our site anonymously without identifying yourself during your visit. We will only obtain information that personally identifies you when you specifically choose to provide it.
For example, during your visits to our web site you may:
You will then need to give us certain personal information just as you would if you were communicating with us in person, by mail or by telephone.
11. Information collected via our website
When you visit and browse our website, we may collect information for statistical, reporting, maintenance, security, marketing and other purposes detailed below. We may also use advertising and tracking companies to collect this information for us.
The information collected by us is aggregated with other users and will not be used to personally identify you. The information may include:
We use this information:
The types of cookies we use include:
By using these we can better serve you with more relevant advertising across the Google Display Network and measure your interaction with our advertising.
We use remarketing to show you relevant offers on external websites based on your interactions with our website. We don’t record or send any information which can personally identify you. If you would like to opt out of this feature, you may visit the Network Advertising Initiative opt-out.
DoubleClick shares anonymised demographic and interests data with us through the use of third party cookies. We use this information to better understand who is coming to our site and how we can serve them better. You can elect to opt out of this feature at any time through the Google Analytics opt out add on or through updating your Ad Settings on Google.
12. E-mail Communications
If you choose to send us an e-mail message, we may retain the content of the e-mail, your e-mail address, and our response in order to service your needs.
We may update this Privacy and Credit Reporting Policy from time to time for any reason and to ensure it continues to meet the requirements of the Privacy Act, new laws, regulations and technology. We will also post any changes to our Online Consumer Information Practices on our website, so we encourage you to check this page from time to time.
Last updated 6 October 2014