Privacy Policy

 

1. Introduction

 

Symbos Australia Holdings Pty Ltd (‘Symbos’) respects and upholds your rights to privacy protection under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).  With regards to Privacy, Symbos adheres to the APPs which were introduced in 2012.

This policy describes how we manage any personal information we have about you.

In this privacy policy, “we”, “our” and “us” refers to Symbos Australia Holdings Pty Ltd (ACN 616 221 124).

 

2. What personal information about me does Symbos hold?

 

The information Symbos collects is regulated by law. Symbos may hold the following information about you, but is not limited to:

  • Identity information (name, date of birth, gender);
  • Contact details (address, phone or email);
  • Tax File Number and country of tax residency;
  • Medicare card, Australian passport, driver licence, or pension card details;
  • Citizenship, birth, death and marriage certificates (for example, to verify your identity);
  • Foreign passport and driver licence (for example, to verify your identity at the time you request a product or service);
  • Details of your employment, income, assets, financial liabilities;
  • Bank account, credit card details and other financial transaction data including copies of bank statements and credit card statements from financial institutions;
  • Information from third parties about your credit history and insurance claims history;
  • Default, Judgment, Bankruptcy information;
  • Information relevant to the assessment or enforcement of claims against you or another person by our clients;
  • Any information you have provided to us during telephone calls that legislation allows us to record;
  • Use our online services (such our online payment portal or ‘contact us’ webform);
  • Complaint details;
  • Proceedings before any tribunals and any ombudsman complaints and their outcomes; and
  • Video or audio recording/s.

 

We will only collect sensitive information (such as health information) if you have given us express consent to do so, and:

  • The information is reasonably necessary for the ordinary administration of our business; and
  • The use of the information is required or authorised under an Australian law court or tribunal order.

 

3. We collect personal information in a number of ways, including:

 

Symbos collects personal information from various sources. This may include collecting personal information from:

  • Directly from you when you provide information by phone, or through letters sent by you, or when you submit your personal details through our website, fax or email, or through forms sent by us to you to complete.
  • From third parties such as our clients, credit reporting agencies or your representatives and others with whom we may liaise.
  • From publicly available sources of information.

 

We also may collect personal information about employees and prospective job applicants, so that we can meet internal operational requirements, complete business transactions, conduct research, deliver services and provide client support or meet regulatory requirements.

 

4. Information Security Management

 

Symbos is dedicated to keeping the highest quality of information as well as ensuring that your personal information is stored in a secure manner in compliance with the law. The personal information that we keep is secured within systems certified as International Standard – ISO27001 Information Security Management compliant.

 

5. What Does Symbos do with my personal information?

 

We may use personal information about you:

  • To verify your identity;
  • To assist in assessing and enforcing claims on behalf of our clients against you or third parties;
  • To provide customer support and meet regulatory requirements for our internal administration, planning and operations;
  • To report to credit-reporting bodies; and
  • To provide to our business partners who support us in our business functions.

 

Unless you otherwise consent or we are otherwise permitted to do so by law, personal information will only be used or disclosed for the purpose for which it was collected (“the primary purpose”) or for a purpose related, or in the case of sensitive information directly related, to the primary purpose (“the secondary purpose”).

Symbos may disclose personal information about you to any person in the ordinary administration of our business, such as for data processing, printing or mailing, recovery of receivables and engaging lawyers to prosecute claims. Symbos may also use or disclose information where it is required or permitted by law to do so.

Personal information may also be disclosed to third party suppliers for data-washing and location purposes in the course of our business operations as permitted or required by law.

Personal information that is collected by Symbos will be used by and disclosed to Symbos employees in Australia, and where contractually permitted, to our employees in New Zealand, Fiji and South Africa whose duties require them to use it. Employees that will have access to your information are trained in the protection, handling, usage, management and disclosure of your personal information in accordance with the Privacy Act.

Where Symbos does not collect your personal information, we may be unable to identify, contact or provide our services to you in an efficient and timely manner.

 

6. Openness

 

You may request access to personal information we hold about you by writing to the “Privacy Officer” at the address below.  Where we hold information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you access it.

However, we may not be able to tell you what Personal Information we hold about you in certain circumstances, including where the information relates to legal matters in which you are involved, and the information would be confidential, commercially sensitive or legally privileged information.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it.  We will consider if the information requires amendment.  If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

Any questions about this policy, or any complaint regarding treatment of your privacy by Symbos, should also be made in writing to the Privacy Officer at the following address:

The Privacy Officer
Symbos
PO Box 13159
Law Courts
Melbourne VIC 8010

Or via email at privacyofficer@recoveriescorp.com.au c/o Recoveries Corporation Pty Ltd.

If you are not happy with the response we have provided, you can make a complaint to the Office of the Australian Information Commissioner (OAIC) by calling 1300 363 992, online by visiting their website, or by writing to the OAIC at GPO Box 5218, Sydney, NSW, 2001.

 

7. Disposal of information

 

Symbos takes reasonable steps to destroy or de-identify the personal information it holds once the it is no longer needed for any purpose for which the personal information may be used or disclosed under the APPs. This requirement does not apply where Symbos is required by legislation, regulation, contract, law or a court/tribunal order to retain the personal information for a fixed period.

Symbos may retain your personal information for a period of seven (7) days to seven (7) years subject to our client instructions.

 

8. Complaints

 

We would appreciate if you would first allow us the opportunity to resolve the complaint through our Internal Dispute Resolution Scheme. You can contact our complaints officer at:

The Privacy Officer
Symbos
PO Box 13159
Law Courts
Melbourne VIC 8010

Or via email at privacyofficer@recoveriescorp.com.au c/o Recoveries Corporation Pty Ltd.

If you are not satisfied with how your complaint has been handled, or the resolution provided by us, you can request us to escalate your complaint to the Australian Financial Complaints Authority (AFCA), for independent external review.

Australian Financial Complaints Authority (AFCA). Complaints can be lodged with AFCA in one of the following ways:

 

If your complaint relates to a privacy matter, you can contact the Office of the Australian Information Commissioner (OAIC):

  • Website: oaic.gov.au
  • Telephone: 1300 363 992
  • In writing: Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001

Please note there are time limits for lodging complaints with AFCA or OAIC, which are available by contacting each organisation directly.

In certain cases, we may ask you to refer your complaint to an alternative EDR scheme when appropriate, particularly if the issue predates Symbos’s involvement with the account.

 

9. Disclaimer

 

In this policy, “personal information” has the same meaning as under the Privacy Act. We may change this policy from time to time. Although we intend to observe this policy at all times, from time to time we may regard it as necessary or desirable to act outside the policy. Symbos may do so, subject only to any other applicable contractual rights you have and any statutory rights you have under the Privacy Act or other applicable legislation.