This Is the Verifier Privacy Policy
This is what you are agreeing to when you use Verifier.
Effective date: 19 June 2024
This Privacy Policy explains how Verifier Australia Pty Ltd (together “Verifier”, “we”, “us” or “our”) collects, uses, discloses, and secures personal information in connection with services provided by Verifier.
We comply with the Privacy Act and the Australian Privacy Principles (APPs), upon which this policy is based. This Privacy Policy applies to personal information we collect from individuals and from third parties.
1. Changes to our Privacy Policy
Our Privacy Policy is effective as of the date indicated above. Please visit our website regularly as we update this Policy from time to time. We will let you know about changes by indicating on the Privacy Policy the date it was last updated and making such updated Privacy Policy available on our website. We may also choose to notify you of material changes to our Privacy Policy by email or by publishing a notice on our website.
2. What “personal information” means
When we say “personal information” we mean information that specifically identifies a person, or from which a person is reasonably identifiable. For example, a person’s name, date of birth, address, phone number, email address, driver’s licence number, bank account number, employment information or superannuation fund information.
Information about how we use “cookies” and similar technologies is set out at the end of this Privacy Policy.
3. Collection of personal information
A. If you use our services when making a loan application
We collect personal information from individuals when they use our verification services in connection with making a loan application to a lender. The personal information we collect may include identity and contact details, and other personal details such as financial information. We do not collect “sensitive information”, such as health information.
We also collect personal information from lenders considering loan applications and other organisations who hold personal information to assist individuals to verify their identity or their financial information to those lenders.
B. If you interact with us through our website
If you interact with us through any website that we operate (other than when you use our services in connection with making a loan application to a lender) we may collect your personal information, including identity and contact details.
C. If we are a service provider to an organisation you interact with
We will collect personal information from you and from third parties when we need to do so to provide our services to an organisation you interact. For example, if you are applying for hardship relief or going through a hardship review process. We also collect your personal information from the organisation we provide our services too. The personal information we collect may include identity and contact details, and other personal details such as financial information. We may also collect “sensitive information”, such as health information.
D. If we provide you a service that uses Consumer Data Right data
We also provide services to our customers, using personal data collected securely, and in accordance with the rules defined by the Consumer Data Right (CDR).
Our CDR policy tells you how we handle and manage your personal data under the CDR law.
Why we collect, use and disclose personal information
We collect, use and share personal information so that we can:
provide our services
assist individuals to verify their identity and financial information
administer and improve our services
manage our risks
conduct and improve our business and improve our user experience
comply with our legal obligations
We may disclose personal information to:
our data sources (that is, organisations who hold personal information we access on behalf of individuals to assist them to verify their identity, their employer, or their financial information). In this case, we may disclose personal information to a data source to enable access to information that data source holds, to administer and improve our services, or to enable the data source to update personal information it holds that is out-of-date;
organisations individuals interact with, where we provide our services to those organisations (that is, organisations who use our services to automate their internal business processes); and
our service providers who perform functions on our behalf. If so, we require them to keep that personal information confidential and secure, and to use it only as is reasonably necessary to carry out their work on our behalf or comply with their legal obligations.
We disclose personal information about individuals to our data sources, organisations we provide our services to and our service providers to enable us to provide our services. When an individual uses our verification services in connection with making a loan application to a lender, we will disclose personal information to that lender only when the individual has given us their express consent and has directed us to do so.
4. Collection of anonymous information
If you use our MoneyPulse financial wellbeing service
We do not collect any personal information from individuals (or from anyone else) when they use our MoneyPulse financial wellbeing service to answer our survey questions. In addition to survey responses, we collect de-identified data about a person’s loan from that person’s lender so that we can give a person who answers our survey informed insights about their financial wellbeing. A lender will give us a unique number (which does not include any personal information) so that we can link the de-identified loan data to the relevant survey response without personally identifiable information being shared.
This means that individuals who use our MoneyPulse service do so anonymously.
We will include the anonymous data to prepare analysis and identify trends. We will share data from this set of anonymous data with lenders who offer our MoneyPulse service to their customers or members, to help them learn more about how to deliver better service, and to understand the impact of their services on their customers or members. We do not share any individual survey answers with lenders.
We will also share data from the set of anonymous data with our academic research partners.
5. Marketing
If we collect personal information in connection with a loan application or as service provider
When we collect personal information from individuals who use our verification services in connection with making a loan application, or when we provide our services to an organisation, we do not use or disclose that personal information for direct marketing purposes.
If we collect personal information by other means
Otherwise, when we collection information from individuals by any other means (for example, where individuals download our publications and other materials from our website) we may use and disclose that personal information to tell you about our products and services.
6. Keeping personal information secure
We keep personal information in our electronic records. These records are kept in our systems (or those of our related companies). We do not keep personal information in hard-copy records.
We have administrative, technical and physical safeguards designed to ensure the security, confidentiality and integrity of personal information.
Generally, where practical, we keep information only for as long as required (for example, to meet legal requirements, the requirements of organisations we provide our services to, or our internal needs).
If we collect personal information in connection with a loan application
However, when we collect personal information from individuals who use our verification services in connection with making a loan application, we keep that personal information for between one month and six months (depending upon the type of service we have provided to collect the personal information), after which we will either destroy or de-identify the personal information.
7. Sending personal information outside Australia
We do not disclose personal information to anyone who is not located in Australia. However, when we disclose personal information to a lender in Australia (at your request) that lender may use processes that involve disclosure to persons who are not located in Australia.
8. Accessing, updating and correcting personal information
Getting access
Individuals can ask for access to the personal information we hold about them, by getting in touch with us using the contact details in section 10. We will not charge a fee for making an access request or for giving access to personal information.
We aim to make personal information available as soon as reasonably possible after access has been requested. We will need to confirm identity before the requested personal information is provided.
The Privacy Act allows us to deny a request, or limit the access we provide, in certain circumstances. For example, we might not provide access to commercially sensitive information. If we do deny or limit access, we will explain our decision in writing.
Updating and correcting personal information
If individuals think that any personal information we hold about them is inaccurate, they can ask us to correct it by contacting us using the details in section 10. If the personal information that is corrected is personal information we have provided to others, the individual can ask us to notify those others of the correction. There is no fee for these requests.
If we do correct personal information as requested, we will let the individual know when we have done so. However, if we disagree that personal information is inaccurate and should be corrected, we will give our reasons in writing. An individual can ask us to include a statement with the disputed information, indicating their view that the information is inaccurate, misleading, incomplete, irrelevant or out-of-date.
9. Resolving concerns
Individuals who have a concern about their privacy have a right to make a complaint.
Complaints can be made by getting in touch with us using the contact details in section 10. We will acknowledge complaints and provide a name, a reference number and contact details of the person responsible for reviewing the complaint.
We will do everything we can to address concerns and put matters right. Our aim is to resolve the matter straight away if possible. However, if we can’t give our final response within 45 days, we’ll make contact to explain why and discuss a timeframe to resolve the complaint.
10. Contact detailS
Our Privacy Officer: Debra Kruse - privacy@verifier.me
11. Cookie Policy
On our website we use cookies to allow our statistics module to determine if a website visitor is unique.