Pharmapac Credit Reporting Policy (Draft)
We are committed to being open and transparent about how we manage your credit information and credit eligibility information. We encourage you to read this Credit Reporting Policy carefully. It will help you make informed decisions about sharing your credit information with us.
This Credit Reporting Policy applies to any individual or organisation who applies to Pharmapac for commercial credit, provides a guarantee for commercial credit, or has any dealing with Pharmapac in connection to the provision of commercial credit or a guarantee for commercial credit.
Credit reporting policy
This Credit Reporting Policy sets out how Pharma Pac Ltd NZBN 9429037119812, its related companies and affiliates (referred to as "we", "us", "our" or "Pharmapac") manage credit information, credit eligibility information and credit reporting information under the Privacy Act 1988 (Cth) (Privacy Act), Privacy Regulations 2013 (Cth) and Privacy (Credit Reporting) Code 2014. Pharmapac is a credit provider in relation to commercial credit only under Part IIIA of the Privacy Act.
Please note: Pharmapac is obliged to notify you, or ensure you are made aware of, certain matters at or before the time we collect credit information that we are likely to disclose to credit reporting bodies. For more information, please refer to the section: When do we disclose your credit information?
Changes to this policy
We may amend this Credit Reporting Policy from time to time and will notify you of any changes by positing an updated version of the policy on our website or by sending you a notice via email. It is your responsibility to check this Credit Reporting Policy periodically for changes, and to keep your email address with us current.
This policy was last updated on: [9 November 2021]
Credit information and credit eligibility information
In this Credit Reporting Policy, we use the terms "credit information" and "credit eligibility information" as defined in the Privacy Act.
Generally, "credit information" refers to personal information about an individual in respect of is credit-related dealings with us, including identifying information, the amount of credit applied for, repayments and defaults.
"Credit eligibility information" is credit reporting information received from a credit reporting body and any further information a credit provider derives from the credit reporting information.
What information do we collect and hold?
Pharmapac may collect credit information and credit eligibility information about an individual, including:
- identification information, such as an individual's name, marital status, address and date of birth;
- the note we make of the credit information disclosed in an information request, so that we can obtain credit information from a credit reporting body;
- the type of commercial credit and the amount of credit sought in an application that has been made by the individual and in connection with which we have made an information request;
- information which relates to the individual's dealings with other credit providers;
- consumer credit liability information, default information, payment information, new arrangement information and publicly available information concerning consumer credit which the individual has obtained from other credit providers;
- credit worthiness information about the individual that credit reporting bodies derive from the above information. This could include credit scores, risk ratings and other evaluations;
- the individual's court proceeding history, including information about a judgment of an Australian court against the individual in proceedings (other than criminal proceedings) that relate to any credit that has been provided to, or applied for by, the individual; and
- personal insolvency information about the individual as entered or recorded in the National Personal Insolvency Index. This information relates to whether the individual has:
- ever been bankrupt or is in the process of going bankrupt; or
- proposed or entered into a debt agreement.
Pharmapac will not hold any credit provider derived information.
How and when do we collect credit information?
We collect your credit information and credit eligibility information when you apply for a trading account with us in the course of providing you with our goods.
Credit information and credit eligibility information may be collected in a number of ways. We may collect credit information directly from you, including via application forms you complete or in our ongoing dealings with you.
When it is not practical or reasonable to do so Pharmapac will collect information from a third party. The third party could be an authorised representative (such as a broker, agent, accountant or lawyer), another financial institution, a referee, an employer or a government body that is permitted to provide us with the information.
Credit eligibility information is obtained from a credit reporting body.
How do we use your Credit information?
Pharmapac uses credit information and credit eligibility information as reasonably necessary for its business activities, including for the following purposes:
- if the individual is a customer or an associate of the customer, to determine if we should provide a facility which includes the provision of commercial credit to the individual and, if we decide to provide it, to assist in the provision of the facility. This includes the assessment of the application, managing the account, recovering money, enforcement of the facilities and dealing with security the individual provides, including providing data analysis for internal management;
- if the individual is a guarantor, to determine whether a guarantee should be accepted from the individual and, if the guarantee is given, to deal with or enforce the rights under the guarantee and any security which may be given to secure it;
- if the individual is a debtor or an associate of the debtor, to assess and verify the debt which a customer sells to Pharmapac or in which a customer provides Pharmapac with a security interest, to collect the debt and to enforce the debt and any security which may be given to secure payment of the debt;
- to undertake securitisation activities, raise funding, assign debts and other rights, enter into insurance arrangements (for example insurance policies for debts) and provide information to and obtain information from insurers (including under policies which are taken out by Pharmapac, which are assigned to us or under which we are the loss payee);
- to deal with complaints, legal proceedings and to meet regulatory requirements; and
- to assist other credit providers in accordance with an authorisation which the individual has provided to Pharmapac.
When do we disclose your credit information?
We may disclose your credit information to a credit reporting body. If you fail to meet your payment obligations to us or commit a serious credit infringement in relation to credit provided by us, we may be entitled to disclose this information to a credit reporting body as well.
An individual has the right to request that the credit reporting body exclude their credit reporting information for the purposes of pre-screening of any direct marketing by us. The individual also has the right to request that the credit reporting body not use or disclose their credit reporting information if the individual believes that he or she has been, or is likely to be, the victim of fraud (for example, the individual suspects someone is using his or her identity details to apply for credit). The individual must contact the credit reporting body directly should this be the case.
You may contact the credit reporting bodies Pharmpac discloses information using the details below:
- Equifax Australian Information Services & Solutions Limited
- Website: www.equifax.com.au
- Mail: PO Box 964, NORTH SYDNEY NSW 2059
- Dun & Bradstreet (Australia) Pty Ltd
- Website: www.dnb.com.au
- Mail: PO Box 7405, MELBOURNE VIC 3004
Generally, we do not disclose credit information and credit eligibility information to overseas recipients.
However, we may do so in limited circumstances. For example, if a debtor is located overseas, we may need to send an individual's credit information overseas so that we can collect the debt.
Pharmapac's head company, Pharma Pac Limited, operates in New Zealand and it will sometimes be appropriate for us to provide credit information and credit eligibility information to that company to assist in the provision of facilities.
We may outsource certain functions or activities to third party service providers located overseas. In each case, we will disclose credit information and credit eligibility information to such overseas recipient in accordance with the Privacy Act.
[Note to Pharmapac: other than NZ, does Pharmapac disclose credit information to other overseas locations? The locations of any other overseas third party entities Pharmapac is likely to disclose credit information will need to be included in the policy.]
Storage and security
Pharmapac takes all reasonable steps to ensure that an individual's credit information and credit eligibility information is protected from misuse, interference or loss and from unauthorised access, modification or disclosure. This is achieved by having physical, electronic and procedural safeguards in place that protect the information we hold. Credit information and credit eligibility information is stored in secure office premises or in secure archiving facilities. Logins and passwords are required to access electronic databases.
Employees of Pharmapac are required to maintain the confidentiality of credit information and credit eligibility information and access to such information is restricted to persons who require the information to perform their duties. Where practical, we only keep credit information and credit eligibility information for as long as is required to meet legal requirements or our internal business purposes.
How you can access or correct your credit information
An individual may request access to their credit information held by Pharmapac. The individual can request access by contacting Pharmapac's Privacy Contact Officer by email at: email@example.com.
Pharmapac will need to verify an individual's identity before giving access to any information requested. The requested information will usually be provided by us within 30 days of receiving a request. There is no charge to make a request, but an administration fee may be charged for providing access to credit information. Pharmapac will provide written reasons if it does not make the requested personal information available.
If an individual considers that any credit information held by Pharmapac about them is incorrect, the individual may request that Pharmapac correct the information. In certain situations, Pharmapac may decide to decline a request to correct credit information. If a correction request is declined, written reasons will be provided by us.
Pharmapac have an internal dispute resolution system that covers complaints. That system complies with ISO 10002-2006 Customer Satisfaction – Guidelines for Complaints Handling in Organisations: sections 4, 5.1, 6.4, 8.1 and 8.2.
If an individual considers that we have failed to comply with Division 3 of Part IIIA of the Privacy Act, the Credit Reporting Privacy Code or the Australian Privacy Principles you should contact our Privacy Contact Officer.
A complaint will be acknowledged within 7 days of receipt and a decision will be made and advised within 30 days (or a longer period as may be agreed with the individual). If the individual is not satisfied with our decision, they may make a complaint to the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are:
- Telephone: 1300 363 992
- Website: oaic.gov.au
- Mail: The Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
We take your privacy concerns seriously. If you have any questions about our Credit Reporting Policy, please contact our Privacy Contact Officer at firstname.lastname@example.org.