Privacy Policy

Over Fifty Seniors Equity Release Pty Ltd (Over Fifty) recognises the importance of safeguarding your privacy and are committed to complying with the Australian Privacy Principles which set the standard for how organizations should deal with personal information. The Australian Privacy Principles (the APPs) are found in amendments to the Privacy Act 1988 which are effective from 12 March 2014.

We trust that this Privacy Policy will help you to understand how Over Fifty collects, uses, discloses and manages your personal information.

This Policy is made available on the Over Fifty web site overfifty.com.au/privacy and you may also request a free copy in an appropriate form.

You also have the option of not identifying yourself to Over Fifty or you may use a pseudonym. We can provide you with general information on Over Fifty and its loan products in these instances. You will be required to identify yourself where required by law or it is impractical not to do so. Examples include making a change to a loan, requesting personal information or lodging a complaint.

We need to collect personal information about you to provide you with loan and mortgage services. This privacy statement tells you how we collect information, what we use the information for and who we share the information with.

What information do we collect?

The type of information collected by us will depend upon your relationship with Over Fifty and may include:

name and title
address
contact details
date of birth
credit history
bank account details
detail on your appointed attorney, next of kin, nominated executor, beneficiary accountant, and solicitor details.

How we collect your information

In most cases, and wherever possible, Over Fifty will try to collect personal information only from you. Information will be collected through various company forms and from you directly, either in writing or verbally. We may also collect information about you from third parties, including:

Introducers including mortgage brokers and financial advisers
Credit reporting bodies
Our service providers
Public information (for example, from public registers, social media and websites) or made available by third parties to update your contact details)
Other third parties you have authorised
Your solicitor or other agents if you authorise us to do so

We exchange information with your legal or financial advisors or other representatives.

How your information is held

Borrower information is held internally and with external loan servicing and custodial service providers.

Generally personal information is stored electronically with hard copy records retained and archived with an archival service provider.

Generally, we do not combine or link other personal information held about you. The exception is when you have multiple loans with us. In these situations, all loans are linked under one client profile.

All internal systems are subject to the security measures detailed in this policy. All external service providers are contractually required to hold personal information in accordance with the Privacy Act.

How do we use your Personal Information?

Over Fifty collects personal information about you primarily:

to provide you with the products and services you request
to provide you with the information you request
to verify your identity before transactions are processed, your instructions are carried out, or providing you with information about your loan
to administer and manage your loan
to respond to your enquiries or complaints
to prepare internal reporting that includes identifiable customer and borrower information (e.g. complaints or issues reporting, loan servicer reporting) to satisfy any legal requirements.

Anti-Money Laundering and Counter Terrorism Legislation

The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) is aimed at addressing money laundering in Australia and the threat to national security caused by terrorism. This legislation requires us to collect identification information from customers and borrowers and to verify your identify from original or certified copies of specified documents or perform electronic verification. Details of what identification information and documentation you are required to provide are set out in transactional based forms. We may also contact you to follow up and clarify certain information.

Under this legislation we are also required to monitor transactions to identify any suspicious activity within any of our loan products.

As required under the AML/ CTF Act, we may, in our absolute discretion, without notice to you, disclose or otherwise report details of any transaction or activity, or proposed transaction or activity (including any personal information) to the relevant reporting body.

Disclosure of Personal Information

Personal information held by Over Fifty may be disclosed to third parties such as:

outsourced service providers, including for management and administration of products and services such as loan servicers, trustees, trust managers, custodians, mortgage and settlement services, and registry and platform service providers
printers and mailing houses, and information technology systems
software providers, actuaries, professional advisers and research organisations
mortgage intermediates such as mortgage brokers, mortgage originators and mortgage managers
valuation service providers and valuers
business partners, including insurance underwriters
government agencies including the Australian Prudential Regulation Authority (APRA), Australian Securities and Investments Commission (ASIC), Australian Transaction Reporting and Analysis Centre (AUSTRAC), Centrelink, Office of the Australian Information Commissioner (OAIC) or the Australian Taxation Office (ATO)
related companies
credit reporting bodies, where a person is in default in relation to loan or other credit arrangements
financial intermediaries such as financial advisers, financial planners and taxation or accounting advisers
other third parties you have authorised to receive your personal information.

Where Over Fifty contracts with an outsourced service provider or business partner we take reasonable steps to protect the privacy of any information disclosed to them, including to comply with the Privacy Act.

Credit reporting

If you make an application for credit, Over Fifty can access a copy of your individual credit report from a Credit Reporting Body (CRB) to help us make a decision about whether or not to grant the application.

We may also disclose your credit information to a CRB if you fail to meet your payment obligations to us, or if you commit a serious credit infringement, in relation to consumer credit for our products or services.

In turn, the CRB may include your personal information in credit reporting information they provide to other credit providers.

Disclosure to entities in other countries

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. If your information is stored in this way, disclosures may occur in countries other than those listed.

Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

We trust that this Privacy Policy will help you to understand how Over Fifty collects, uses, discloses and manages your personal information.

This Policy is made available on the Over Fifty web site overfifty.com.au/privacy and you may also request a free copy in an appropriate form.

What information do we collect?

The type of information collected by us will depend upon your relationship with Over Fifty and may include:

name and title
address
contact details
date of birth
credit history
bank account details
detail on your appointed attorney, next of kin, nominated executor, beneficiary accountant, and solicitor details.

How we collect your information

Introducers including mortgage brokers and financial advisers
Credit reporting bodies
Our service providers
Public information (for example, from public registers, social media and websites) or made available by third parties to update your contact details)
Other third parties you have authorised
Your solicitor or other agents if you authorise us to do so

We exchange information with your legal or financial advisors or other representatives.

How your information is held

Borrower information is held internally and with external loan servicing and custodial service providers.

Generally personal information is stored electronically with hard copy records retained and archived with an archival service provider.

How do we use your Personal Information?

Over Fifty collects personal information about you primarily:

to provide you with the products and services you request
to provide you with the information you request
to verify your identity before transactions are processed, your instructions are carried out, or providing you with information about your loan
to administer and manage your loan
to respond to your enquiries or complaints
to prepare internal reporting that includes identifiable customer and borrower information (e.g. complaints or issues reporting, loan servicer reporting) to satisfy any legal requirements.

Anti-Money Laundering and Counter Terrorism Legislation

Under this legislation we are also required to monitor transactions to identify any suspicious activity within any of our loan products.

Disclosure of Personal Information

Personal information held by Over Fifty may be disclosed to third parties such as:

outsourced service providers, including for management and administration of products and services such as loan servicers, trustees, trust managers, custodians, mortgage and settlement services, and registry and platform service providers
printers and mailing houses, and information technology systems
software providers, actuaries, professional advisers and research organisations
mortgage intermediates such as mortgage brokers, mortgage originators and mortgage managers
valuation service providers and valuers
business partners, including insurance underwriters
government agencies including the Australian Prudential Regulation Authority (APRA), Australian Securities and Investments Commission (ASIC), Australian Transaction Reporting and Analysis Centre (AUSTRAC), Centrelink, Office of the Australian Information Commissioner (OAIC) or the Australian Taxation Office (ATO)
related companies
credit reporting bodies, where a person is in default in relation to loan or other credit arrangements
financial intermediaries such as financial advisers, financial planners and taxation or accounting advisers
other third parties you have authorised to receive your personal information.

Credit reporting

In turn, the CRB may include your personal information in credit reporting information they provide to other credit providers.

Disclosure to entities in other countries

Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

Credit reporting

If you make an application for credit, Centuria can access a copy of your individual credit report from a Credit Reporting Body (CRB) to help us make a decision about whether or not to grant the application.

In turn, the CRB may include your personal information in credit reporting information they provide to other credit providers.

Declining Product or Service Offers (Opting-out)

From time to time Over Fifty may wish to use your information to tell you about other products, services or special offers that we think may be of interest to you. Please let us know if you do not want to receive these offers by contacting us using the contact details noted below or selecting the unsubscribe option in an email.

Quality of Information

Over Fifty aims to ensure that the personal information we retain about you is accurate, complete and up to date. Please provide us with complete and accurate information and keep us informed of any changes in your details such as a change of address.

If you do not provide all or part of the personal information that we request, we may not be able to contact you or to administer your loan properly.

If you believe that the information we hold about you is inaccurate please contact us directly using the contact details provide below, so that we can update our records.

Security of Information

Over Fifty will at all times take steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. Your personal information is treated as confidential.

Employees and contractors of Over Fifty and its related parties are bound by confidentiality obligations. Passwords, firewalls and virus protection are used by Over Fifty with a view to ensuring the security and integrity of the information technology systems that hold your information.

All premises housing our systems and other copies of your information are monitored and protected by security alarms and access card or key lock entry. Service providers who hold personal information are contractually required to hold information in accordance with the Privacy Act.

DATA Breaches Notification

We will promptly notify you if we are aware of or have reasonable grounds to believe that your Personal Information held by us is involved in an eligible notifiable data breach and involves Personal Information being lost or subjected to unauthorised access or unauthorised disclosure which is likely to result in serious harm. Our notification to you will include recommendations about the steps you should take in response to the breach, and will not be anytime longer than 30 days from when the determination has been made by our management that the breach may cause serious harm. We will also notify the OAIC of the data breach.

Our assessment and escalation of such breaches will be in done in accordance with our Incident & Breach Reporting policy and procedures.

Your Rights of Access and Correction

You are entitled to obtain access to your personal information subject to some exceptions allowed by law. You may also request that Over Fifty correct or update information that we hold on you. We encourage our customers and borrowers to ensure that their personal information is accurate and up to date, particularly mailing address and contact details.

If you wish to make a request for access to your personal information, please contact us using the contact details below.

Contact Details

Over Fifty and all other privacy enquiries

Phone: 03 9616 6523 during business hours, or by writing to Over Fifty Customer Services, GPO Box 695, Melbourne Vic 3001 or email [email protected].

Complaints

If you wish to make a complaint about a possible breach of privacy or how we have handled your personal information, please contact us on 03 9616 6523 during business hours or address your complaint to:

Complaints Manager
Over Fifty Seniors Equity Release Pty Ltd
GPO Box 695
Melbourne Vic 3001

or email [email protected].

Over Fifty will acknowledge your complaint in a prompt manner and investigate. We will contact you to advise the outcome and aim to resolve the complaint within 30 days. If you are not satisfied with our response, you may also be able to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).