CREDIT REPORTING POLICY

Purpose and application of this policy

This document is the Credit Reporting Policy of Saputo Dairy Australia Pty Ltd (ABN 52 166 135 486) and its related bodies corporate (we, us, our). It describes how we will comply with the credit reporting obligations contained in the Privacy Act 1988 (Cth) (Privacy Act) and the Credit Reporting Code as registered under section 26S(1) of the Privacy Act.

In this Credit Reporting Policy, “credit-related information” means credit information, credit eligibility information and CRB derived information as those terms are defined in the Privacy Act.

We may provide products or services to you on credit (i.e. you will pay us for those products or services after we start providing them to you). We may conduct a credit check on you (or your directors, partners or other authorised representatives) before you become a customer of ours or a member of our co-operative.

The Privacy Act and this policy do not apply to credit provided to companies or other entities who are not individuals. However, this policy will apply where we request that a director, partner or other authorised individual guarantees the credit to be provided by us to a company or other entity, but only in respect of any uses of that individual’s credit-related information as part of our assessment of the suitability of that individual as a guarantor.

Collection of credit-related information         

We may collect, hold, use and disclose credit-related information about you. We may obtain this information from you or from third parties, including from credit reporting bodies, industry bodies and other entities which are also a credit provider to you, in order to assist us in determining whether we will provide any products or services to you (or to your related company or other entity) on credit.

In particular, we may collect the following items of credit-related information about you:

• your name, address (current and previous 2 addresses) and contact details;
  
  
• your date of birth, gender, marital status, number of dependents;
  
  
• your banking or credit card details;
  
  
• a statement of your assets and liabilities and other financial information and supporting documentation;
  
  
• details of your trade credit history;
  
  
• if relevant, the name of your employer;
  
  
• your driver’s licence number, tax file number or Australian Business Number (as applicable);
  
  
• details of your other applications for consumer credit or commercial credit;
  
  
• information about any credit provided to you by other credit providers (such as financial institutions, utilities or telecommunications providers), including any credit that you have applied for or guaranteed;
  
  
• details of your credit history, including details of any credit defaults and any repayments missed or late repayments that you have made in relation to any credit provided to you;
  
  
• any credit rating or credit assessment score that we have calculated or that is provided to us by a credit reporting body;
  
  
• details of any credit-related court proceedings or insolvency applications that relate to you;
  
  
• the fact that any instalments of credit payments are overdue or that your repayments are no longer overdue; and
  
  
• the fact that credit provided to you by third parties has been paid or otherwise discharged.

Use and disclosure of credit-related information

We may use the credit-related information that is collected and held by us to help us decide whether or not to provide credit to you (or to your related company or other entity). We may also use this information to derive or calculate a credit assessment score in relation to you, which we will then use to help us in conducting our assessment of your creditworthiness.

The purposes for which we use and disclose your credit-related information may include:

• using your credit-related information to assess any application that you make to us for credit in relation to the products or services that we supply to you (or to your related company or other entity);
  
  
• using your credit-related information to collect payments that are owed to us in respect of any products or services that we have previously supplied to you (or to your related company or other entity) on credit;
  
  
• disclosing your credit-related information to any of our related companies that are also are considering whether to provide credit to you (or to your related company or other entity);
  
  
• disclosing your credit-related information to a third party where you have asked that we provide a trade reference for you (or to your related company or other entity);
  
  
• where you have offered to guarantee credit that we have offered to provide to your related company or other entity, to assess your suitability as a guarantor of that credit and to enforce that guarantee if required;
  
  
• disclosing your credit-related information to a third party that you or we ask to act as a guarantor of any credit provided to you;
  
  
• disclosing your credit-related information to the credit reporting bodies that we deal with, including Illion Australia Pty Ltd and Equifax Pty Ltd. Credit reporting bodies collect different types of credit-related information about individuals and use that information to provide a credit-related service to their customers (including to us);
  
  
• disclosing your credit-related information to our related companies and to our contractors and service providers (including any third party or industry body or association who acts as a credit reference agency or provides a credit reference service to us);
• disclosing your credit-related information to other third parties that provide services to us. These might include debt collectors, credit management agencies, other third parties that process applications for credit made to us and to our professional advisors (including lawyers, accountants, auditors and bankers);
  
  
• disclosing your credit-related information to other credit providers which provide, or are considering providing, credit to you (or to your related company or other entity);
  
  
• using and disclosing credit-related information that we hold about you to assess and respond to any access or correction requests that you lodge with us;
  
  
• where we are consulted by a credit reporting body or another credit provider about an access or correction request that you have lodged with those entities, to respond to that consultation request;
  
  
• where you complain to the Information Commissioner or any provider of a recognised external dispute resolution scheme about our treatment of your credit-related information, to respond to that complaint and to seek legal or other professional advice in relation to your complaint;
  
  
• using and disclosing credit-related information that we hold about you as required by law or the order of a court or tribunal; and
  
  
• where you otherwise expressly consent to the use or disclosure.

Where required by law, we will make a written note (which may be kept in electronic form) of any use or disclosure that we make relating to your credit-related information.

Location of your credit-related information

We may also disclose your credit-related information to third party service providers and our related companies which are located in Canada or in the United States or to any successor in interest to its business by merger, sale of assets, reorganization, operation of law or otherwise.

Security and quality of your credit-related information

We will take reasonable measures to make sure that the credit-related information that we collect, use, hold and disclose about you is accurate, complete and up-to-date and (in relation to the purpose of our use or disclosure) is relevant to that purpose.

We take reasonable steps to ensure that the credit-related information that we hold about you is protected from misuse and loss and from unauthorised access, modification or disclosure. Except to the extent specified otherwise in this Credit Reporting Policy, we will securely store all credit-related information that we collect or hold about you in an electronic system located in Australia.

We store information in different ways, including in hardcopy and electronic form. We have implemented certain organisational controls to help us protect your credit-related information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Access and correction of your credit-related information

You have a right to request access to any credit-related information that we hold about you. If you would like to access the credit-related information that we hold about you, please contact us using the contact details set out below.

Where we hold credit-related information about you, we provide you with access to this information upon request, including by posting or emailing it to you if you request access to your information in those particular manners. We will generally provide access to you within a reasonable time but may refuse to provide access where we are permitted to do so by law.

You also have a right to request that we correct any credit-related information that we hold about you if you believe that this information is inaccurate, out-of-date, incomplete, irrelevant or misleading. You can make such a correction request by using the contact details set out below. We will respond to your request within 30 days (or such longer period as you may agree or we may request).

We will not charge you for making a request for access or for making any corrections to your credit-related information. However, we may in some circumstances charge a reasonable administrative fee to cover our costs of providing access to you.

If we cannot respond to your correction request without consulting with other credit providers or credit reporting bodies in relation to your request, we may do so and these bodies are permitted by law to assist us in resolving your correction request.

If we agree to your request, we will promptly correct any credit-related information that we hold about you that we are satisfied is inaccurate, out-of-date, incomplete, irrelevant or misleading. If we do correct your credit-related information at your request, we will inform you and each other credit provider and credit reporting body to which we have previously disclosed that information that we have corrected your information. Where we disclosed your credit-related information after you made a complaint but before it was resolved, we will tell the recipient that you have made such a complaint and we will subsequently inform that entity of the outcome of your correction request.

If we have any other reasons for suspecting that credit-related information that we hold about you has become inaccurate, out-of-date, incomplete, irrelevant or misleading, we may independently decide to correct this information without consulting you. If we do this, we will take reasonable steps to notify that correction to you and to any other entities to which we have previously disclosed that credit-related information (unless it is impracticable for us to do so).

Complaints

You have a right to complain about any failure by us to comply with the Privacy Act or the Credit Reporting Code in relation to our handling of your credit-related information.

If your complaint relates to our failure to provide access to your credit-related information or to our failure to correct any credit-related information that we hold about you, you may lodge a complaint directly with the Office of the Australian Information Commissioner (OAIC) (for more information, please see www.oaic.gov.au).  If we are required by law to be a member of an external dispute resolution scheme, you may instead lodge your complaint with that organisation. If this applies, we notify you of this and the identity of our external dispute resolution provider at the time that you make a credit-related complaint

If you have a complaint in relation to our handling of your credit-related information that is not mentioned above, you must first lodge your complaint with us using the details set out at the end of this policy and provide us with details of the incident so that we can investigate it.

Our procedure for investigating and dealing with complaints (other than those that can be made directly to the OAIC or an external dispute resolution provider) is as follows:

1. complaints should be made in writing and submitted to us using the contact details below;
2. we will treat your complaint confidentially. Our representative will investigate your complaint and contact you within a reasonable time after receipt of your complaint to discuss your complaint and the options available to you to resolve it;
3. we will endeavour to make sure that your complaint is resolved within a reasonable time of receiving your complaint (and in any event within the time required by the Privacy Act, if applicable); and
4. if you are not satisfied with our handling of your complaint or our proposed resolution, you have a right to lodge a further complaint with the OAIC. If we are required by law to be a member of an external dispute resolution scheme, you may instead lodge your further complaint with that organisation. If this applies, we notify you of this and the identity of our external dispute resolution provider at the time that you make a credit-related complaint. These bodies will then provide you with further information about the next steps in their complaints process.

Where your complaint relates to the correction of your credit-related information and the resolution of your complaint requires us to correct your information, we will inform each other credit provider and credit reporting body that we have previously disclosed your information to that that you have made a correction complaint in relation to that information and that we have corrected your information as a result of the outcome of that complaint. However, if it is impracticable or illegal for us to do give such a notification, then we cannot be required by law to give this notification and we will not do so.

Contacting us

If you have any questions about this Credit Reporting Policy or if you have any concerns or a complaint regarding the treatment of your credit-related information, you should contact our Privacy Officer using the details set out below.

Changes to our Credit Reporting Policy

We may change this Credit Reporting Policy from time to time, including in order to comply with any future amendments to the Privacy Act 1988 (Cth), the Credit Reporting Code or related laws or regulations. Any updated versions of this Credit Reporting Policy will be effective from the date of posting on our website. 

This Credit Reporting Policy was last updated in January 2020.