Privacy Policy

Like you, we care about ensuring that personal and private information you entrust us to hold is protected and secure. This Statement outlines the personal information we need and how we collect, hold, disclose, use and share it. For examples of the personal information we may need see Section 3.2.

Each member of the Scholar Mortgage is committed to protecting and handling your personal information in accordance with the law including the Privacy Act 1988 (Cth) (‘Privacy Act’).

2. What you need to know

We will take reasonable steps to protect your information.
We will comply with the notification requirements of the Privacy Act if we are aware of your information being lost or compromised.
We will never sell your information to a third party.
We use information we collect from you and from other sources to provide services to you and to improve how we operate and provide those services.
If you have concerns or questions about how we use or handle your information, get in touch with us at info@scholarmortgage.com.au.

3. Collection, use and sharing of personal information

3.1 Why do we collect your information?

We collect personal information to enable us to provide our services to you. We collect personal information relating to you and your financial requirements, in order to assist with providing you with home loan products and services. If you don’t want to or are unwilling to provide us with the information we need, we may be unable to provide services to you.

3.2 How do we collect your personal information?

We collect your personal information directly from you. We may also collect information about you from other sources, for example:

your representatives such as a solicitor or conveyancer;
joint applicants, co-applicants, or guarantors;
referral partners, who refer your business to us;
publicly available information such as public registers or social media;
your employer;
other organisations we partner with to provide products or services to you; and
credit reporting bodies.

We collect personal information when you:

enquire about, apply for, or use our products or services;
speak to us about a loan application or a product or are a party to such loan application or product (for example, a joint applicant, co-applicant, guarantor, or director or trustee of a corporate or trust loan applicant);
give us feedback or to make a complaint;
visit our website or use our digital services;
participate in other activities we offer, such as competitions or surveys; or
talk to us or do business with us.

When you give us personal information about another person, you acknowledge that you are authorised by that person to do so and agree to inform that person of the contents of this document.

Examples of the personal information we may collect include:

Personal and contact details

Name, address, email address, phone number, date of birth, photographs, and audio recordings (including information contained in the recordings).

Australian Government, or foreign government identifiers and identity documents

Australian driver licence, passport, Medicare card, or pension card details;
Foreign identity documents;
Citizenship or birth certificates;
Company names, numbers and details; and
Country/countries of tax residency.

Financial information

Details of your recent and current employment, income, assets, financial liabilities;
Information from third parties about your credit history; and
Documents to help us verify your financial information, for example, payslips, tax returns, financial statements, bank statements, loan statements, credit card statements, and confirmation of employment from your employer/s.

Credit information

See section 5.3 for the types of credit information that we may collect.

Socio-demographic information

Marital status, age, gender, number of dependents, occupation, and nationality.

Interaction information

Details of your interactions with us, such as when you use our online services, speak to us, meet our brokers, or visit our stores. We may monitor and record our calls with you. You expressly provide us with your consent to record your telephone and online conversations with us.

Usage analytics

See section 5.4 for the types of usage analytics we may collect.

Sensitive information

We may collect and handle sensitive information, including:

health information (for example, where this is relevant to your financial situation, or to an insurance policy or claim, or if you’re in financial difficulty and ask for hardship relief due to illness); or
race or ethnicity (for example we may ask you what language you speak if you are not fluent in English).

Camera surveillance

For the safety of our team members and customers, we may use camera surveillance such as Closed-Circuit Television (CCTV). We will let you know if CCTV is present at the location you visit.

Information about your personal circumstances

We may ask you to provide information about your personal circumstances to provide you with support, for example:

information about significant life events such as a death in the family or relationship breakdown;
information about family or domestic violence;
where you have been impacted by an emergency event or natural disaster; or
details of an injury or illness or gambling or addiction.

Publicly available information

We may collect and handle information that is in the public domain, such as from:

online forums, websites, Facebook, Twitter, YouTube or other social media platforms (for example, if you use social media to make a complaint); or
public registers (for example, those kept by the Australian Securities and Investments Commission).

3.3 How do we use your information?

How we may use your information

Serving you as a customer

To provide you with third party (if applicable) products and services. This may include:

verifying your identity;
assessing your eligibility for lender’s products;
assisting you with online applications;
assessing, processing, and submitting your application for credit and providing you with information about related insurance products;
telling you about third party products or services;
managing our relationship with you or your business; and
better understanding you and your needs and improving our service, products, and your experience.

Managing our operations and improving our business

For internal purposes, including reporting and analysis.
Systems development and testing purposes.
Learning which areas of the websites are of most interest to you (see Cookies and web beacons).
Responding to complaints and seeking to resolve them.
Reviewing and responding to your feedback and assessing how you use our products or services.
Monitoring and reviewing call recordings, online chats and other business activities for quality assurance, training, and compliance purposes.
Managing corporate governance, and audit.
Understanding and managing our risks.

Complying with our legal obligations

Meeting our legal and regulatory obligations.
Sharing relevant information with law enforcement, government and regulatory bodies.
Identification, investigation and prevention of criminal activity.
Investigating health and safety issues.

De-identifying information

We de-identify your information in order to provide anonymised datasets to other organisations, or for the purpose of generating insights and analytics.

3.4 Who do we share your information with?

We will never sell your information. We will share your information:

across the company, including with our brokers and credit representatives;
to external organisations to help us deliver the services we provide to you; and
to other third parties with your consent, such as lenders to whom you make an application.

Before we share your information with any third party, we conduct reasonable and appropriate checks on that third party. We may share your information with the following types of third parties:

Our panel of lenders/credit providers

Your information will be provided as part of your credit application or a referral. If your information is provided for a loan application, the lender may list a credit enquiry on your credit file and will report certain details about your credit information to credit reporting bodies.

Government and law enforcement agencies

We may share your information with regulatory bodies, government agencies, the police, external dispute resolution bodies and law enforcement agencies.

Credit reporting bodies (CRBs)

We may provide your information to CRBs to obtain a report from them as an ‘access seeker’ (this will not appear on your credit report or impact your credit score). We may also disclose information about you to a CRB when you are applying for credit, you have obtained credit via us, or if you guarantee or are considering guaranteeing the obligations of another person to us. When we give your information to a CRB, it may be included in reports that the CRB gives other organisations (such as other lenders) to help them assess your credit worthiness. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get obtain credit from other lenders.

Authorised third parties

We may share information with third parties where you have authorised us to do so (either through express consent or where your consent may be reasonably inferred). They include:

parties we have a relationship with to enable you to enquire about the services or products they offer; for example, insurance or consumer asset finance products;
any person who proposes to guarantee or has guaranteed repayment of any credit provided to you;
co-applicants/joint applicants; or
third parties you have authorised to act for you (such as accountants, legal representatives, financial councellors, financial advisors, or persons with a third party authority or power of attorney.

Our service providers

We may share your information with external service providers who we engage to do some of our work for us, for example mailing houses, legal service providers, marketing agencies, marketing research companies, information technology providers and cloud service providers.

Other third parties

Our auditors and insurers.
Organisations that assist us to identify, investigate or prevent fraud, cybercrime, or other misconduct.
Organisations involved in our funding arrangements.
Any person considering acquiring or taking an interest in our business.
As required by law.

3.5 Location of information we hold about you

We may hold or process your information on servers located overseas. When we do this, we make sure there are appropriate data handling and security arrangements in place to protect your data. If our team members, brokers, and credit representatives perform their duties from overseas they will only use authorised systems and processes.

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

As electronic or networked storage can be accessed from anywhere via an internet connection, it is not always practicable to know which country your information may be held in. If your information is stored in this way, disclosures may occur from time to time in countries other than those listed here or those we referred to.

4. Holding and protecting your information

We protect your information in a number of ways, including:

confidentiality requirements of our team members and brokers;
document storage security policies;
security measures for access to our systems;
only giving access to personal information to authorised or verified people;
control of access to our buildings; and
oversight from our Cybersecurity team and security engineers to ensure that security controls are in place and effective.

We have a plan that is designed to enable us to contain, assess and respond to suspected data breaches in a timely fashion, and to help mitigate potential harm to affected individuals.

Much of the information we hold about you will be stored electronically (such as electronic documents and audio recordings). Some information we hold about you will be stored on paper files until such time that it is uploaded to our systems and securely destroyed.

Our cybersecurity program and governance are aligned to industry standards, and we strive to meet or exceed standard security benchmarks. However, security incidents and data breach events can occur. If you have reason to believe that your interaction with us has been compromised, please contact us immediately using the details provided in How to contact us below.

We will keep your personal information while you are a customer of the Group. We generally keep your personal information for up to 7 years after you stop being a customer, but we may keep your personal information for longer:

to fulfil legal or regulatory obligations;
for internal research and analytics; or
to respond to a question or complaint.

If we receive information about you that we did not request or need, and if we decide we did not collect the information in accordance with this Statement and applicable Privacy Laws, we will take reasonable steps to destroy or de-identify the information.

When we no longer require your information, and we are legally permitted to, we will take reasonable steps to destroy or de-identify the information. If it is impossible or impractical to completely remove the information, the same security safeguards will be in place to protect the information, as detailed in this Statement.

5. Other relevant matters

5.1 E-consent

By providing your email address and then clicking submit on our website, online form, application, calculator, tool, or query, you acknowledge that communication and document sharing may be electronic and not paper based. You acknowledge that electronic communications must be regularly checked. You may withdraw your consent to provide documents by electronic communication at any time.

5.2 Opting out of direct marketing

You can let us know at any time if you no longer wish to receive direct marketing offers from us by:

contacting us using the details provided in How to contact us below;
contacting your broker; or
using the method outlined in the marketing materials.

We will not charge you for opting out. We will process your request as soon as we can, however it may take a few days for your profile updates to be reflected in our systems.

5.3 Credit information

Credit information is a sub-set of personal information and may include information in relation to any loans that you have outstanding, your repayment history, opened and closed dates and any defaults. Usually, credit information is exchanged between credit providers and credit reporting bodies ‘CRBs’). Credit information held by the CRBs has a bearing on an individual’s credit worthiness and is used to establish the individual’s eligibility for credit.

We may ask CRBs to give us your overall credit score and may use credit information from CRBs, together with other information to arrive at our own assessment of your ability to manage credit.

You authorise us to obtain a copy of your credit report from a CRB as an ‘access seeker’. As an ‘access seeker’ our enquiry will not appear on your report or impact your credit score. You consent to us providing information contained in that report (including arrears, credit, and personal information) to any credit provider who you authorise us to do so, and who may be able to provide credit to you.

We may disclose your credit information to joint applicants or co-borrowers.

You have the right to request access to the credit information that we hold about you and to directly request a CRB to correct that credit information. You may also contact a CRB to advise them that you believe that you may have been a victim of fraud. For 21 days after the CRB receives your notification, the CRB must not use or disclose that credit information.

5.4 Cookies and web beacons

A ‘cookie’ is a small text file placed on your computer by a webpage server that may later be retrieved by webpage servers. We use cookies on our websites to provide you with a better website experience. When you visit one of our websites or related landing pages to read, browse, submit or download information, our system will record/log your IP address, date and time of your visit to our site, your user identifier (in some scenarios), the pages viewed and any information downloaded. We may automatically collect non-personal information about you such as the site from which you linked to our websites. You can configure your browser to refuse cookies or delete existing cookies from your hard drive. Rejecting cookies may have the effect of limiting access to, or functionality of, parts of our website.

Web beacons

A web beacon is typically a transparent graphic image invisible to the user that is placed on a website or in an email. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel. We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and “advertising/marketing personalisation”. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing Third-Party networks and websites (Third-Party Websites) such as Google and Facebook.

5.5 Changes to our Privacy Statement

We may update our Privacy Statement and procedures from time to time to help ensure we keep up to date with market expectations, legislative updates, practices and technology. Our latest Statement will be available:

on our websites;
by request using the contact details in How to contact us below; and
directly from our brokers.

6. Personal information about employees, credit representatives, or employee or credit representative applicants

We will also collect personal information from you if you:

apply for a job with, and/or become employed by us; or
apply to become a credit representative or become a credit representative under one of our Australian Credit Licences.

In these circumstances, you:

consent for us to collect any personal information (whether written or verbal) from any referee or previous employer specified in your application for employment or curriculum vitae for evaluation of your application for employment and to hold such information on your personal file for future evaluation of your employment by us;
acknowledge that your personal information is collected for the purpose of evaluating your application for employment by us or your application to become a credit representative of ours;
acknowledge that should you accept employment with us or become a credit representative of ours, your personal information is collected and held for the purpose of assessing your continued engagement with us and the administration by us of your remuneration and contractual obligations; and
acknowledge that a failure by you to provide the requested personal information will have a detrimental effect on our ability to give your application proper consideration. You can request to access and/or correct your personal information in accordance with this Statement at any time.

7. Managing and accessing your information

7.1 Accessing and correcting your information

We need your help to ensure the information we hold is up to date and accurate. If you move or change contact details, please let us know as soon as possible.

If you need to access information that we hold about you, we can provide this to you by contacting us by using the details in How to contact us below.

There is no fee to ask for your information, but sometimes we might charge a fee to cover the time we spend gathering the information you want. We can provide you with general information, such as your name, address and contact details quite easily but other information may take longer to provide. If there’s a fee, we’ll let you know how much it is likely to be, so you can choose if you want to go ahead. You’ll need to make the payment before we start.

We will try to make your information available to you or to correct your personal information within 30 days of the date of your request.

In some cases, we can refuse access or only give you access to certain information. If we refuse to give you access to or correct your information, we will give you written notice setting out the reasons for the refusal and the mechanisms available for you to complain about the refusal.