Privacy Policy | Commercial Credit Control

Privacy Policy

Commercial Credit Control Pty Ltd (CCC) is committed to adhering to the AUSTRALIAN PRIVACY PRINCIPALS and on behalf of its clients and their customers. This policy outlines our obligations to you and how we manage your personal information.
From 12 March 2014, the Australian Privacy Principles (APPs) replaced the National Privacy Principles and Information Privacy Principles and will apply to organisations, and Australian Government (and Norfolk Island Government) agencies.
A copy of the Australian Privacy Principles may be obtained from the website: 

https://www.oaic.gov.au/agencies-and-organisations/guides/australian-privacy-principles-and-national-privacy-principles-comparison-guide


 

1Compliance

 

CCC has adopted the Australian Privacy Principles (APPs) from Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988.  CCC manages all personal information in an open and transparent way and ensures that all employees are aware and comply with the Australian Privacy Principals (APP). A copy of our privacy policy has been signed by all staff members and is displayed internally through intranet and available on our website.

2. Anonymity

Wherever it is lawful & practicable, individuals have the option to interact anonymously with CCC.

3. Collection of Personal Information

CCC is a licensed collection agency, acting on behalf of Clients whom have authorised it to collect alleged outstanding debts – and no other purpose. 

Information that we collect includes: names, addresses, account information supplied by our clients, email addresses, phone and fax numbers. Personal information is only obtained by lawful and fair means and not in an unreasonably intrusive way. Personal information is obtained in several ways;

  • supplied by our Clients for the purpose of collection an alleged outstanding debt
  • From web searches of public domain information (e.g. White Pages)
  • From credit bureaux
  • From you or a Third Party authorised ONLY by you.

At or before the time (or, if that is not practicable, as soon as practicable after) Commercial Credit Control Pty Ltd collects personal information about an individual, Commercial Credit Control Pty Ltd will make the person aware of: -

(i) Why we are collecting information about them 
(ii) To whom the information may be passed 
(iii) And, for any other specific reason Commercial Credit Control Pty Ltd will if it is reasonable & practicable to do so, collect personal information about the individual from that individual

 4. Sensitive Information

CCC does not collect sensitive information about an individual unless the circumstance arises as set in AUSTRALIAN PRIVACY PRINCIPAL 4.

5. Openness

CCC will provide this document which clearly expresses the policies on its management of personal information to anyone who asks for it. Also on request by a person, CCC will take reasonable steps to let the person know, generally, what sort of personal information it holds, for what purposes, and how it collects, holds, uses and discloses that information.

6. Use and Disclosure

CCC will only use and disclose personal information for the primary purpose and will be guided by the relevant sections of AUSTRALIAN PRIVACY PRINCIPAL 6.
CCC only uses personal information gained as stated above and for the sole purpose of collecting alleged outstanding debts – no other purpose. Your information is disclosed only to you, upon request, and to our Clients. The only exceptions to this are, if you authorise, in writing, a Third Party to represent you, or where required by law. CCC may disclose personal information to its third party mailing house for the purpose of sending notices and correspondence to you. The mailing house is PCI compliant; hence data is handled in accordance with PCI-DSS standards. Data is ‘shredded’ using a PGP Shredder the day after it is used. This is a robust method of deleting sensitive data and ensures that data files  cannot be recovered.

7. Direct Marketing

CCC will not use or disclose personal information for the purpose of direct marketing.

8. Transborder Data Flows

CCC may transfer personal information about an individual to someone (other than organisation or the individual) who is in a foreign country as outlined in AUSTRALIAN PRIVACY PRINCIPAL 8.

9. Identifiers

CCC will not adopt as its own identifier of an individual an identifier that has been assigned by another organization as set out in AUSTRALIAN PRIVACY PRINCIPAL 9.

10. Data Quality

CCC takes great care to protect the personal information it collects, uses or discloses is accurate, up-to-date and complete. It is important that you advise us at the earliest opportunity of any changes to your Personal Information, whilst your account is active, so that our records can be updated. Your data is maintained for statutory periods. Your personal information is not cross-referenced with other clients’ accounts.

11. Data Security

CCC takes safe steps to ensure that the personal information it holds is immune from misuse and loss and from unauthorised disclosure, access or modification.  All data is username and password protected and access is limited to information, depending on job function. As soon as an employee leaves the company, passwords are changed and their access denied. Firewalls are in place and up-to-data virus software is constantly scanning. Hardware is stored in locked computer cabinets, in a locked room. Back-to-base security is in place. Back-ups are run and regular restores tested. Data security improvement is a continuing process. CCC’s security policies and practices are consistent with AS/NZS ISO/IEC 27002:2006. All staff, contractors and agents are required to sign a Non Disclosure Agreement  confirming that they have read and undertake to adhere to the requirements of The Privacy Act 1988 (Cth), including the Privacy Amendment (Private Sector) Act 2000. CCC will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under AUSTRALIAN PRIVACY PRINCIPAL 11.

12. Access

You have the right to access the personal information that we hold about you. If you wish to access personal information, you may do so by utilising any of the contact methods provided at the end of this policy. CCC will not charge any fee for your access request and providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing such information.

13. Correction

Once you have accessed your personal information that we hold about you and if you are able to establish that the information is not accurate, complete and up-to-date, we will take reasonable steps to correct the information. We request that any change to your information be advised in writing to our office by utilising any of the contact methods provided at the end of this policy. CCC will not charge any fee for changes made to your Personal Information.

Privacy Policy Enquiries

Mail: Commercial Credit Control Pty Ltd
GPO Box 746
Brisbane Qld 4001
Tel:    1300 73 1166
Fax:   07 5585 5077
Email: cs@comcredit.com.au
Web: www.comcredit.com.au