Privacy Policy: FirstPoint Mortgage Brokers

Who are we?

‘We’, ‘us’ and ‘our’ refer to Mortgage Asset Services ABN 96 101 790 434, Australian Credit Licence 391771 (MAS) and our credit representative Firstpoint NB Financial Solutions Pty Ltd ABN 13 124 920 832, Australian Credit Licence 520856 (Firstpoint) and our related businesses.

To contact us, please see details under the heading ‘Further information’, below.

Our commitment to protect your privacy

We understand how important it is to protect your personal information. The following sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for 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.

Personal information

Personal information is 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 a sub-set of personal information. When we refer to credit information, we mean information which is used to assess your eligibility to be provided with finance and includes any finance that you have outstanding, your repayment history and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies. Please see the heading Credit information, below.

The kinds of personal information we collect about you include your name, date of birth, contact details such as residential address and home and mobile phone numbers, account details, occupation, and any other information necessary to identify you. If you are applying for finance, where required we will 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 will also collect your health information. We will only collect health information from you with your consent. Please see the heading ‘Sensitive information’, below.

Why we collect your personal information

We collect (as well as hold, use and disclose) personal information for the purposes of assessing your application for finance and managing that finance, and to conduct our business, such as to comply with our legal obligations. We will 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. Please see the heading Direct marketing, below.

How do we collect your personal information?

Where reasonable and practical, we will collect your personal information directly from you, including from your use of our websites or mobile apps. Please note that our websites may contain links to third party websites (for example, third party providers of goods and services). We do not guarantee website links or policies of any such third parties.

If required, we will also collect your personal information from publicly available sources as well as from credit reporting bodies and third parties, including finance brokers, accountants, lawyers and your representatives.

How do we disclose your personal information?

Your personal information will be exchanged between MAS and our authorised corporate credit representative, Firstpoint, for the purposes stated above.

Further, 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, lenders mortgage insurers, trade insurers and credit reporting bodies;
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;
to investors, agents or advisers, or any entity that has an interest in our business; or
to any joint applicants/borrowers and guarantors, your employer and referees, or identity verification services.

We may use and disclose your personal information for identity verification via the Australian government’s Digital Verification Service (DVS). The DVS is a national secure online system, which enables authorised entities to electronically verify identity documents issued by a range of Australian, State and Territory government agencies. If you have any questions around our online identity verification process, please contact us. For more information on the DVS, see https://www.idmatch.gov.au. If you do not authorise your personal information being disclosed to the DVS, we may not be able to verify your identity.

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.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located in or outside Australia. We may also hold your personal information in paper form.

Credit information

We may collect the following kinds of credit information from credit reporting bodies and other entities:

credit liability information being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;
repayment history information which is information about whether you meet your repayments on time;
information about the type of finance that you are applying for;
default and payment information; and
court proceedings information.

We collect this credit information for the purposes of assessing your application for finance and managing that finance.

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

When we obtain credit information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

Notifiable matters

The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information. You may request to have these notifiable matters (and this privacy policy) provided to you in an alternative form by contacting us.

We use the credit information from credit reporting bodies to confirm your identity, assess your creditworthiness, assess your application for finance and manage your finance.

We may exchange your credit information with credit reporting bodies. The information we may exchange with credit reporting bodies includes your identification details, what type of loans you have, how much you have borrowed, whether or not you have met your loan payment obligations and if you have committed a serious credit infringement (such as fraud). If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a credit reporting body.

You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed. Please see the heading ‘Access and correction to your personal and credit information’, below.

Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way.

You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification, the credit reporting body must not use or disclose that credit information. You can contact any of the following credit reporting bodies for more information:

Direct marketing

From time to time, we may use your personal information (other than sensitive information, unless we have your consent) 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 telephoning us on 02 9527 2230 or by writing to us at 1A/19-21 Gerrale St, Cronulla NSW 2230. 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.

Collecting third parties’ personal information

If you provide to us personal information about other individuals (for example, the name and contact details of your authorised representatives), you should inform them that you are doing so and advise them they can contact us for further information.

Notifiable data breaches

The Privacy Act includes a Notifiable Data Breaches (NDB) scheme which requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain data breaches and recommend steps you can take to limit the impacts of a breach.

The NDB scheme requires us to notify about a data breach that is likely to result in serious harm to affected individuals. There are exceptions where notification is not required. For example, where we have already taken appropriate remedial action that removes the risk of serious harm to any individuals.

If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts onto your privacy. If you believe that any personal information we hold about you has been impacted by a data breach, you can contact us.

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 ask that you 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 (including credit information) we hold about you. You may request access to any of the personal information we hold about you at any time by contacting us. 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 will 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.

If we deny you access to the personal information we hold about you, we will provide you with an explanation.

If any of the personal information we hold about you is incomplete, inaccurate, or out of date, you can 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 other finance providers or credit reporting bodies or 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 will 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. If you choose not to provide certain personal information (for example, your date of birth), we may not be able to provide you with the products and services you require, or the level of service we aim to offer.

Sensitive information

Sensitive information a sub-set of personal information and includes information relating to your racial or ethnic origin, religious or philosophical beliefs, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health. We will only collect sensitive information about you if it is reasonably necessary for our functions or activities and with your consent.

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 will also take reasonable steps to protect any personal information from misuse, interference, and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

contractual arrangements with service providers;
confidentiality requirements of our employees;
document storage security policies, such as our Information Security Policy;
security measures for access to our systems;
only giving access to personal information to a person who is verified to be able to receive that information;
control of access to our buildings; and
electronic security systems, such as firewalls and data encryption on our websites.

We also regularly review developments in security and encryption technologies. However, it is important to remember that the use of email and the internet may not always be secure, even with these safeguards in place.

When we no longer require your personal information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in this policy. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or if you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer on 02 9527 2230.

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 Australian Financial Complaints Authority scheme, which can be contacted on 1800 931 678, or the OAIC, who can be contacted on either www.oaic.gov.au or 1300 363 992.

E-consent

By providing your email address and then clicking submit on any online form, calculator, tool or query, you consent to receiving notices and other documents from us by email to the email address provided, and you understand that if you give this consent: we may no longer send you paper copies of notices and other documents; you should regularly check your email account for documents; and you may withdraw your consent to receiving documents by email at any time. You also confirm that you have the facilities to print any notice or document that we send you by email, if required.

Further information

You may request further information about the way we manage your personal or credit information by contacting us:

Change in our privacy policy

We are constantly reviewing all of our policies and attempting to keep up to date with market expectations. Technology is constantly changing, as are the law and market place practices.

As a consequence, we may change this privacy policy from time to time or as the need arises. The latest privacy policy is available on our website. You may request this privacy policy in an alternative form.

This policy was last reviewed on 31.01.2023.

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