At Challenger, we understand your concerns about privacy and the security of your personal information. Your privacy is important to us and we are bound by the Privacy Act 1998 (Cth) and the National Privacy Principles ("NPPs"). We are committed to protecting the personal information that we hold about you.
1. What personal information is collected?
Challenger only collects personal information that is reasonably necessary for us to perform our functions. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:
- information you give us when you request a product or service from us. This information may include your name, address, contact details and relevant identification documents;
- communications between us and your financial adviser or mortgage broker;
- communications between us an associations that you are a member of and with which we have an affiliation;
- transactional information about the use of a product if you have or had a product with us;
- financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks; and
- in a limited number of circumstances such as in some superannuation products, your personal health information.
2. How personal information is collected?
Challenger collects your personal information in a number of ways including:
- directly from you (including via your financial adviser or mortgage broker), such as when you provide the information by phone, email or in an application form;
- from other Challenger group companies; and
- from third parties such as credit reporting agencies or credit providers, if you authorise us to do so.
3. What if you do not provide certain information?
If you choose not to disclose your Tax File Number ("TFN"), TFN exemption or Australian Business Number ("ABN"), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments.
If you choose not to disclose your account details or correctly answer verification questions, we will not be able to process transactions requested.
If you provide us with an incomplete application, we may not be able to provide you with the product or service until the application is complete.
If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.
4. Use and disclosure of your personal information
Challenger may use your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:
- to verify your identity or transactions which you may enter into with us;
- to administer and manage the provision of our products and services;
- to respond to queries, complaints or to provide you with our general customer services;
- to provide your nominated financial adviser with details of your investment;
- to confirm your membership of an association with which we have an affiliation;
- to assess credit which you seek from Challenger loan programmes and to administer any credit a Challenger loan programme provides, including providing your nominated mortgage broker with details of your loan;
- to provide you with offers of other Challenger products or services;
- to provide you with offers from organisations with whom we have an alliance;
- to comply with laws and regulatory requirements including complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
- to comply with Challenger's risk management policies and procedures; or
- to train our staff.
We will not, however, use your personal information other than for:
- a purpose made known to you;
- a purpose you would reasonably expect;
- a purpose required or permitted by law; or
- a purpose otherwise authorised by you.
5. Use of service providers
We may contract out some of our functions such as mailing, settlement services or identification verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.
6. Keeping us up-to-date
Personal information such as contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us in writing. Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form (such as a change of bank account from which direct debits are deducted).
7. Storage and security of information
Challenger stores personal information in a combination of computer storage facilities, paper-based files and other records. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modification or disclosure.
Once personal information is no longer required to be retained, it is either destroyed or permanently de - identified.
9. Access and correction
Generally, Challenger will provide you with access to your personal information that we hold, unless particular exception applies, such as where:
- it would be unlawful to provide the information;
- providing access would be likely to prejudice an investigation of possible unlawful activity;
- it would pose a serious and imminent threat to the life or health of any individual; or
- the request is frivolous or vexatious.
If a request for access would divulge a commercially sensitive decision-making process, then Challenger may provide an explanation rather than direct access to the information.
If you are able to establish personal information that Challenger holds is inaccurate, incomplete or out-of-date, then we will amend it. If you and Challenger disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.
Challenger does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier. Instead, Challenger-issued numbers such as investor numbers and account numbers are used to identify individuals and the Challenger products and services they obtain.
Given legal requirements on financial institutions to identify their customers, in most situations Challenger is unable to allow you to transact with it on the basis of anonymity. However, access to the Challenger public website, and some other interactions with Challenger may be done anonymously.
12. Transborder data flows
Challenger may transfer personal information to locations beyond Australia in the course of storing that information and when using or disclosing it for one of the purposes referred to above. When transferring personal information to foreign jurisdictions, Challenger will only do so where the recipient is subject to binding requirements similar to those in Australia.
13. Sensitive information
Challenger only collects sensitive information where required by law or where the collection has been consented to.
If you would like more information about how we manage your personal information, please contact us on +61 2 9994 7000, or write to us at the following address:
The Privacy Officer
Level 15, 255 Pitt Street
Sydney NSW 2000
If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. For more information on how you may lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hotline service on 1300 363 992.
Use of our web site
We will collect some information from you when you visit the Challenger website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.
Challenger uses third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information. For more information on our web analytics providers, please visit Omniture and Google Analytics.
The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. We will record your email address if you send us an email.
Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.