Privacy Policy

Last updated: December 2024

About us

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

 

Our commitment

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

This Privacy Policy sets out:

    • the kinds of personal information we collect
    • the reason why we collect and use your information
    • how we handle personal information, including sensitive information and credit information
    • important information about credit reporting matters
    • information about the use of your information for the purpose of providing credit and obtaining lender’s mortgage insurance (LMI) where required (including how this information is collected and used by the lenders mortgage insurer)

We will tell you how we collect and use your information when you complete an application 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 available on our website.

 

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 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 or that is related to our business or your potential employment with us. Where it is practical to do so, we will collect your personal information directly from you. We may collect this information in a number of ways including when you submit a form, through a websites or app, or by communicating with us directly over the phone or in person at a branch. 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
    • relationship information
    • occupation, 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), tax residency status, Medicare card number, or Australian Business or Company Number (ABN or ACN)
    • health information
    • details about when and how you interact with us including 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 which we may collect from you or third parties

Credit-related personal information includes information we collect about you when you apply for credit and that relates to your credit worthiness. Credit information may include:

    • identity details such as name, gender, date of birth, address and employment details
    • information about current or prior 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 credit worthiness 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
    • publicly available information about your credit worthiness
    • 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 we may collect, and hold includes any information that has been obtained from a credit reporting body or that we have derived from that information that affects your credit worthiness or may be used to establish your eligibility for credit. This may include our analysis of a credit or loan application you make.

 

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 only collect sensitive personal information when needed and with your specific consent. For example, we may collect information relating to your health when assessing a hardship application.

 

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
    • insurers and reinsurers (for example property of lenders mortgage insurers)
    • publicly available information
    • law enforcement, regulatory bodies, government agencies and other entities that identify or investigate fraud and other illegal activities.

Accessing our website and Cookies

When you use our website, internet banking or mobile banking apps our servers we use cookies which are small files places on your device that gives us information such as your IP address, location, mobile device and network information and third-party websites that you visit.

Cookies perform various functions: Some are session-based that assist with tasks like filling out forms or surveys, while others remain on your device to remember your preferences and settings for future website visits. We use information cookies provide to help us improve and tailor our product and service offerings to you and for other purposes including:

    • assigning an identification number to your internet browser (not used to identify you)
    • checking if your browser has previously visited our website and recalling your settings/preferences
    • monitoring details about your browser interactions which may include your IP address, your browser and device, and connection type and internet provider
    • monitoring and reporting your usage of our website
    • identifying other pages or third-party websites accessed by your browser
    • monitoring preferences related to digital or other media consumption from linked websites that have consented to share information with us
    • personalising your access to services that we provide on our website.
    • enhancing security and detecting fraud

If you are an internet banking customer, we may track your use of our internet banking services and online interactions, including:

    • activity on our websites and internet banking, including the referring website
    • whether you followed links on our website and activity related to targeted advertising
    • monitoring any other information you have consented to share

If we identify you using cookies, we will only use the information we collect in accordance with this Privacy Policy and the Australian Privacy Laws. If you wish to disable cookies you can set your browser to refuse them but if you do this our website may not be easy to use or function in the same way.

 

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 such as lender’s mortgage insurance (where required)
    • 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:

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
    • entities that identify or investigate fraud and other illegal activities
    • security providers that minimise risks and block suspicious behaviour
    • lawyers, conveyancers, accountants, brokers, advisers and agents that are authorised by and represent you
    • suppliers that assist with administrative functions (among others) such as printing and mailing out statements, card production, market research or direct marketing
    • service providers such as mortgage insurers (including lender’s 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
    • any other person that you may approve from time to time

Credit reports

Border Bank is part of the Australian credit reporting system. When you apply for credit (or offer to be a guarantor for someone else) we may request your credit report from a credit reporting body. Credit reports show the history of your credit activities and your credit score which Border Bank will use when assessing your credit worthiness.

We share the following information with the credit reporting 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

Website: equifax.com.au
Phone: 138 332

You can access Equifax’s privacy policy at: equifax.com.au/privacy

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.

 

Lenders Mortgage Insurance (LMI)

This information is relevant where Police Bank will or may be seeking LMI insurance from one or more insurers in respect of the repaying of any credit that Police Bank may provide or in respect of any mortgage that may be given to secure the repayment.

Please note that lenders mortgage insurance (LMI) insures the Bank against loss on default under a mortgage secured credit arrangement the Bank has with you.  You do not receive the benefit of the lenders mortgage insurance policy

Below, each insurer listed is referred to as ‘the Insurer’ for LMI purposes as the mortgage insurer.

Helia Pty Ltd

Level 26, 101 Miller Street NORTH SYDNEY NSW 2060
ABN: 106 974 305
Telephone: 1300 655 422

QBE Lenders’ Mortgage Insurance Pty Ltd

388 George Street, SYDNEY NSW 2000
ABN: 70 000 511 071
Telephone: 1300 367 764

Where Police Bank applies to the Insurer for insurance in connection with:

    • any credit sought by you from Police Bank (whether sought by you alone or with others); or
    • any mortgage and / or guarantee given or to be given by you (whether alone or with others) to secure the repayment or any credit provided or to be provided by Police Bank

The Insurer will be collecting any such personal information for the purposes of:

    • deciding whether to insure Police Bank under an LMI policy
    • assessing the risk of you defaulting on your obligations to Police Bank (whether in your capacity as a loan application or a guarantor)
    • administering and varying the insurance cover including for securitisation and hardship applications
    • verifying information that Police Bank collects about you
    • dealing with claims and recovery or proceeds including, among other things, enforcing a loan in place of Police Bank if the Insurer pays out an insurance claim on your loan
    • conducting risk assessments and management actions involving securitisation, credit scoring, portfolio analysis, reporting and fraud prevention
    • a mortgage insurance purpose relating to you
    • complying with legislative and regulatory requirements; and
    • undertaking any other purpose under the insurance policy the Insurer issues to Police Bank relating to your loan.

Without the provision of your personal information to the Insurer, the Insurer may be unable to process or accept Police Bank’s application for lenders mortgage insurance and Police Bank may be unable to provide the credit requested.

 

Comprehensive credit reporting (CCR)

CCR is a credit reporting system which requires credit providers to share your credit history, with both negative and positive credit data about you with credit reporting bodies. CCR means credit reports present a holistic picture of your credit history that enables the Bank to make informed assessments of your ability to repay credit provided to you and to 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.

 

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 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 limit employees access to your information to ensure it is only accessed when needed. Where permitted by law we will destroy or de-identify information that is no longer needed.

 

Disclosure overseas

We may disclose your information to third parties that are based overseas such as Convera 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.

 

Disclosure overseas by LMI Insurer

Where permitted by the Privacy Act, the Lenders’ mortgage Insurer may disclose information about you to third parties, some of which may be located overseas, which may include, without limitation:

    • Police Bank and other financial institutions/credit providers
    • related companies (whether in Australia or overseas)
    • your referees (including your employer), your legal/financial advisers, guarantors and proposed guarantors of your loan and any brokers or referrers that submitted an application on your behalf
    • government or regulatory bodies as required or authorised by law
    • credit reporting bodies and rating agencies and
    • service providers including but not limited to data consultants, IT contractors, marketing companies, fraud reporting agencies, payment system operators, organisations involved in surveying or registering a security property, securitisation service providers, valuers, other insurers, re-insurers, claim assessors and investigators, agents, contractors, external advisers and, if you are in default, debt collection/debt purchasing organisations and/or mercantile agents.

 

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 contact us where you believe your personal information has been impacted by a data breach.

 

Accessing or correcting your personal information

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 provide reasons where we decline any request.

 

Accessing or correcting your personal information held by the LMI insurer

Subject to the provisions of the Privacy Act, you may have access to and request correction of the personal information held by the Lenders’ mortgage Insurer about you. You may contact the Insurer directly for access to your personal information held (if any) and access the Privacy and/or Credit Reporting Principles of the Insurer by contacting the Privacy Officer of the Insurer using the contact details above.

 

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
    • visit borderbank.com.au/forms/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 We will endeavour to have your concern or complaint attended to and resolved amicably within prescribed timelines.

Making a privacy complaint

If you consider that we have not complied with this Privacy Policy or the Australian Privacy Laws you can make a complaint to us at the details provided above. We will consider and respond to any complaint in accordance with our internal dispute resolution procedure.

If you are not satisfied with our handling of your complaint, you can make a complaint, free of charge, to either Office of the Australian Information Commissioner (OAIC) or the Australian Financial Complaints Authority (AFCA). AFCA offers a free independent dispute resolution service. Please see contact details below:

 

Office of the Australian Information Commissioner (OAIC)

Phone: 1300 363 992
Website: oaic.gov.au
Mail: GPO Box 5218, Sydney NSW 2001, or

 

Australian Financial Complaints Authority (AFCA)

Phone:1800 931 678
Website: afca.org.au
Email: info@afca.org.au
Mail: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001

 

Changes to this Privacy Policy

We can make changes to this Privacy Policy from time to time without notifying you but ordinarily we will notify you of any significant changes.