Who are we?
‘We’, ‘us’ and ‘our’ refers to the Broker, Aggregator, Australian Credit Licensee and our related businesses outlined in the Credit Guide provided to you.
Our commitment to protect your privacy
We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.
Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.
The kinds of personal information we may collect about you include your name, date of birth, address, contact details, account details, occupation, and any other information we made need to identify you.
If you submit inquiries or information using our website we may also collect the type of finance and the amount of finance that you are interested in obtaining, and any information that you provide to us directly through our website or indirectly through use of our website.
If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.
Why we collect your personal information
We collect personal information for the purposes of assessing your application for finance and managing that finance. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services.
We collect personal information on our website to send communications requested by you and to answer enquiries and provide information or advice to you.
To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your finance, or in our business.
How do we collect your personal information?
Where reasonable and practical we will collect your personal information directly from you.
We may also collect your personal information from LM Broker Services, other finance brokers and other people such as accountants and lawyers.
Do we disclose your personal information?
We may disclose your personal information:
- to prospective funders or other intermediaries in relation to your finance requirements;
- to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us;
- to anybody who represents you, such as finance brokers, lawyers and accountants;
- to anyone, where you have provided us consent;
- where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth);
- to investors, agents or advisers, or any entity that has an interest in our business; or
- to your employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
(b) you have consented to us making the disclosure.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to entities and services located outside of Australia, including the following:
- our data hosting and other IT service
- providers, located in various countries; and
- other third parties located in various foreign countries, including Philippines & USA.
Your personal information may be stored in the cloud in an overseas country. If your information is stored in this way, disclosures may occur in countries other than those listed.
In the event that a disclosure is made in an overseas country, the information will be under a foreign law and may not be protected by the Australian Privacy Principles. In any event, by providing your details, you consent to your information being disclosed in this manner.
From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
Access and correction to your personal information
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information. At the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
Using government identifiers
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
Business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
How safe and secure is your personal information that we hold?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact us via the contact link on our website.
We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.
If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.
Effective date: August 2021
What to do if you have a dispute or complaint?
We hope you are delighted with our services, but if you have a complaint please let us know so we can work towards resolving it promptly and fairly.
Making a complaint to us is free.
You can make a complaint verbally or in writing by contacting your broker directly or by using any of the following:
- Email: email@example.com
- Phone: 03 9320 1082 or 1800 763 486 (toll free) Monday to Friday 9am to 5pm (AEST)
- Mail: BLSSA Advice Complaints, Level 15 360 Elizabeth Street, Melbourne VIC 3000
Accessing our policy
If you require accessibility assistance (including language and translations) please use the details above so we can help.
External Dispute Resolution Scheme
If we do not reach an agreement on your complaint, you may refer the complaint to an ASIC Approved External Dispute Resolution (EDR) Scheme. Our external dispute resolution provider is the Australian Financial Complaints Authority(AFCA).
You can contact AFCA using any of the following:
- Online: www.afca.org.au
- Email: firstname.lastname@example.org
- Telephone: 1800 931 678 (toll free)
- Mail: GPO Box 3, Melbourne Vic 3001
External dispute resolution is a free service established to provide you with an independent mechanism to resolve specific complaints. You may refer the matter to AFCA at any time, but if our internal process is still in progress, they may request that our internal processes be completed before considering the matter further.
INTERNAL DISPUTE RESOLUTION PROCEDURES TEMPLATE
We aim to provide the very best service for our clients. In the event that you are unhappy regarding any part of our service, our internal dispute resolution process provides that your complaint will be handled efficiently, honestly and fairly.
De-Arne O’Toole is authorised as a credit representative (Credit Representative number 517860) to engage in credit activities on behalf of BLSSA Pty Ltd (ACN 117 651 760) (Australian Credit Licence number 391237) who may assist us in the investigation and resolution of your complaint.
Should you have a complaint about our services, please contact:
Stanhope NSW 2335
PHONE: 0448 043 136
BLSSA Pty Ltd Complaints Officers:
Level 15, 360 Elizabeth Street
Melbourne VIC 3000
PHONE: 03 9320 1082
TOLL FREE: 1800 763 486
The Complaints Officers are senior personnel in our organisation and in BLSSA Pty Ltd and have the necessary experience and authority to handle your complaint and make relevant decisions on outcomes.
The complaint need not be in writing and may be presented by any reasonable means, for example letter, telephone, post on social media site owned by our organization, email or in person. Please ensure you give us full particulars of your complaint.
If you are not satisfied with the response to your complaint, you may contact the Australian Financial Complaints Authority (AFCA) (of which we and BLSSA Pty Ltd are members) on:
Phone: 1800 931 678
Mail: GPO Box 3 Melbourne VIC 3001
If the complaint is about privacy and you are not satisfied with the outcome of our investigations, you may ask the Office of the Australian Information Commissioner to consider the complaint. The Information Commissioner can be contacted online at http://www.oaic.gov.au/privacy/making-a-privacy-complaint or on 1300 363 992.
All staff and consultants who deal with (or are likely to deal with) clients, are aware of the names, titles and telephone numbers of our and BLSSA Pty Ltd’s Complaints Officers.
Each staff member and consultant is also instructed in how to transfer a client who has a complaint to our Complaints Officer or BLSSA Pty Ltd’s Complaints Officer; and what client details to record if the Complaints Officers are for any reason unavailable (this information will include a minimum of the name, telephone number, and description of the product or transaction to which the complaint relates). We and BLSSA Pty Ltd do not charge any fee in respect to any complaint.
We will provide a written acknowledgement of receipt of the complaint to the client within 24 hours (1 business day) or as soon as practicable unless the complaint is otherwise resolved in the meantime.
We will ensure that a final response is given to you as soon as possible, but within twenty one (21) or thirty (30) days of receipt of the complaint.
If we or BLSSA Pty Ltd are unable to deal with the complaint as it relates to a third party (for example, a lender), we or BLSSA Pty Ltd may ask you to contact the relevant third party.
For certain types of complaints, involving “default notices” or urgent disputes such as “applications for hardship”, a final response must be provided within twenty one (21) days.
Final responses to complaints not involving financial hardship should be received by you within thirty (30) days.
If we cannot respond to you within relevant timeframes, we will inform you within thirty (30) days of the reasons for the delay and of your right to refer the complaint to the Australian Financial Complaints Authority (AFCA) or, in the case of privacy complaints, to the Australian Information Commissioner.
We will have provided a final response to you if we:
(a) Accept the complaint and, if appropriate, offer redress, or
(b) Offer redress without accepting the complaint; or
(c) Reject the complaint.
WRITTEN RESPONSE TO A CLIENT
We will give you a written response to your complaint and the reasons for reaching a particular decision on the complaint. We will adequately address the issues that are raised in the complaint.
Where practicable, our response will refer to applicable provisions in Legislation, Codes, Standards or Procedures.
We will inform you of the contact particulars of our EDR Scheme and, for privacy complaints, the Australian Information Commissioner if you are not satisfied with the outcome of our investigating the complaint.
If we accept the complaint and are of the view that it is appropriate to offer redress to you, that redress may be non-financial as well as, or instead of, financial. If we consider that a financial remedy is appropriate then we will provide compensation for any direct loss or damage caused.
We will, when determining the appropriate remedy, take into consideration the extent of loss or damage suffered by you, relevant legal principles, EDR scheme rules, the MFAA Code of Practice and other relevant codes of conduct and concepts of fairness and relevant industry best practice.
We will keep data concerning the complaint in such form and manner as we think fit and will enable analysis according to:
(a) Type of complaint;
(b) Subject of complaint;
(c) Outcome of complaint;
(d) Timeliness of response.
So that we can identify any systematically recurring problems, we will classify complaints accordingly.
Subject to legal constraints including our privacy obligations, we will make available data collected in respect of the complaint upon request to the EDR Scheme, of which we are a member, and the Australian Securities and Investments Commission.
We will review our Internal Dispute Resolution Procedures at least every three (3) years to ensure that our complaints systems are operating effectively. This document was reviewed on 01 October 2021