Privacy Policy
&
Complaints Handling Procedure
Privacy Policy
&
Complaints Handling Procedure
PRIVACY POLICY
At Laurie O'Brien Equipment Finance Pty Ltd, we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Privacy Policy describes our current policies and practices in relation to the handling and use of personal information.
At Laurie O'Brien Equipment Finance Pty Ltd, we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Privacy Policy describes our current policies and practices in relation to the handling and use of personal information.
What information do we collect and how do we use it?
We will ask you for personal information when we assist you with your finance. Personal information may include any sensitive information (including health information) and may include any information you tell us about any vulnerability you may have. We use the information you provide to advise about and assist with your credit needs. We only provide your information to the companies with whom you choose to deal (and their representatives).
We also use your information to send you requested product information and to enable us to manage your ongoing relationship with us e.g. invoicing, client surveys etc. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
We may occasionally notify you about promotions, new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post. If you would rather not receive this information, email or write to us.
We may also use your information internally to help us improve our services and help resolve any problems.
We will ask you for personal information when we assist you with your finance. Personal information may include any sensitive information (including health information) and may include any information you tell us about any vulnerability you may have. We use the information you provide to advise about and assist with your credit needs. We only provide your information to the companies with whom you choose to deal (and their representatives).
We also use your information to send you requested product information and to enable us to manage your ongoing relationship with us e.g. invoicing, client surveys etc. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
We may occasionally notify you about promotions, new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post. If you would rather not receive this information, email or write to us.
We may also use your information internally to help us improve our services and help resolve any problems.
What if you don’t provide some information to us?
If you don’t provide us with full information, we can’t properly advise or assist you with your credit needs.
If you don’t provide us with full information, we can’t properly advise or assist you with your credit needs.
How do we hold and protect your information?
We strive to maintain the reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We hold the information we collect from you, stored on secured servers.
We ensure that your information is safe by utilising two-factor authentication, strict employee access protocols, and yearly audits of our procedures.
We strive to maintain the reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We hold the information we collect from you, stored on secured servers.
We ensure that your information is safe by utilising two-factor authentication, strict employee access protocols, and yearly audits of our procedures.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
Disclosures to overseas recipients
Some of the recipients to whom we disclose your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include the Philippines, India, and Nepal.
* From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
* You can unsubscribe ‘opt-out’ by notifying us and we will no longer send information to you.
The information we obtain from you is used, subject to compliance with Australia’s privacy and credit reporting laws, only for the purposes listed in this Consent and is not disclosed to any other person except with your permission or as permitted, or required, by law.
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.
Disclosures to overseas recipients
Some of the recipients to whom we disclose your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include the Philippines, India, and Nepal.
* From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
* You can unsubscribe ‘opt-out’ by notifying us and we will no longer send information to you.
The information we obtain from you is used, subject to compliance with Australia’s privacy and credit reporting laws, only for the purposes listed in this Consent and is not disclosed to any other person except with your permission or as permitted, or required, by law.
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.
If you wish to access or correct your personal information please write to <insert name and/or title of Privacy Officer and contact/email address >.
We do not charge for receiving a request for access to personal information or for complying with a correction request. < Describe here the amount or basis on which you will charge for providing access to personal information if any. If you do not propose to charge for this, insert “We do not charge for providing access to personal information”.
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.
If you wish to access or correct your personal information please write to <insert name and/or title of Privacy Officer and contact/email address >.
We do not charge for receiving a request for access to personal information or for complying with a correction request. < Describe here the amount or basis on which you will charge for providing access to personal information if any. If you do not propose to charge for this, insert “We do not charge for providing access to personal information”.
Your consent
By asking us to assist with your credit needs, you consent to the collection and use of the information you have provided to us for the purposes described above.
Your consent
By asking us to assist with your credit needs, you consent to the collection and use of the information you have provided to us for the purposes described above.
Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact Michael Adams, Director & Privacy Officer, 0422-716-113, michael@lobef.com.au.
Complaints & Internal Dispute Resolution
If you do have a complaint, please let us know by email, because if we don’t know about it we can’t fix it. You may also contact us by email addressed to; The Complaints Officer at Michael Adams, Director & Privacy Officer, 0422-716-113, michael@lobef.com.au, please make sure you include as much information as you can.
You should explain the details of your complaint as clearly as you can. You must do this in writing. When we receive a complaint, we will attempt to resolve it promptly.
For more information on your privacy rights please visit www.privacy.gov.au
If you do have a complaint, please let us know by email, because if we don’t know about it we can’t fix it. You may also contact us by email addressed to; The Complaints Officer at Michael Adams, Director & Privacy Officer, 0422-716-113, michael@lobef.com.au, please make sure you include as much information as you can.
You should explain the details of your complaint as clearly as you can. You must do this in writing. When we receive a complaint, we will attempt to resolve it promptly.
For more information on your privacy rights please visit www.privacy.gov.au
COMPLAINTS HANDLING PROCEDUREOriginal Date:01.07.23 This version reviewed: 17.07.23
Laurie O’Brien Equipment Finance P/L established an internal dispute resolution (IDR) and external dispute resolution (EDR) capabilities to ensure access to timely, efficient, effective and cost-effective customer dispute resolution.
The object is to ensure, wherever possible, that complaints or disputes are resolved directly with clients via IDR procedures & if they become entrenched, to preserve customer relationships, maintain cost-effectiveness and improve customer satisfaction through EDR procedures.
As at 2023, The timeframe to provide an outcome of the complaint has reduced. We now have 30 days to mediate and respond in writing to the complainant. If the complaint is closed within 5 business days, then there is no further action required from us.
Commitment:
•A copy of this policy can be collected from our website www.lobef.com.au or will be forwarded on request by fax, email or post. •Telephone complaints can be directed to 0422-716-113 or by email to michael@lobef.com.au.
Resources:
•All staff dealing with customers will help to resolve a complaint.
Analysis and evaluation of complaints.
•We will apply principles of fairness to our response.
Timeliness in response.
•We will endeavour to attend to complaints by the close of the working day following receipt.
Impartiality. •Where customers are unsatisfied with outcomes of the Broadway Internal Disputes Resolution system Broadway is member of an External Complaints Resolution Body, the Australian Financial Complaints Authority, member number 99474.
Preamble:
Australian credit licensees & credit representatives require a dispute resolution system that consists of internal dispute resolution (IDR) procedures & membership of external dispute resolution (EDR) scheme that meet ASIC standards. Persons registered to engage in credit activities are also required to be separate members of an EDR scheme approved by ASIC.
IDR/EDR objectives in the Corporations Act are to promote the confident and informed participation of consumers and investors in the Australian financial system, fairness, honesty and professionalism by those who provide financial services, orderly & transparent markets and the reduction of systemic risks.
IDR procedures will take into account business scale (including the number of representatives or credit representatives), the range of financial products or services, the nature of the customer base and the likely number and complexity of complaints or disputes.
Wherever possible, complaints or disputes should be settled directly with clients through IDR procedures to prevent complaints or disputes becoming entrenched, to preserve customer relationships, maintain cost-effectiveness and improve customer satisfaction.
Definition of ‘complaint’ and ‘dispute’ An expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected.
Applying this definition may result in increased administrative burdens. Therefore where a complaint or dispute is resolved to the customer’s satisfaction by the end of the next business day from when the complaint or dispute was received, the full IDR process (capture & recording the complaint or dispute) is not needed.
Guiding Principles
Commitment; Reasonable steps are needed to ensure consumers and other interested parties know about our IDR procedures, how to make a complaint or dispute, apply for a hardship variation or request a postponement of enforcement proceedings in a convenient and accessible form.
Resources; All staff who deal with customers, not just complaints or disputes handling staff, should also have an understanding of the IDR procedures.
Collection of information: To avoid marginalization of any particular client, complaints or disputes do not need to be in writing but may be made by letter, telephone, email or in person. Where a complainant or disputant has limited literacy skills, the complainant or disputant should be assisted with filling in forms or given help in expressing their complaint or dispute more clearly.
Procedure
1.Complaint received. 2.Once a complaint has been received, you must acknowledge receipt within 24 hours and the acknowledgement must be verbal or in writing.
3.Connective must be notified. Please refer to the email templates below.
4.To finalise the complaint within your IDR process we must provide a written response.
5.The written response to the complainant providing the outcome must include enough detail for the complainant to understand the basis of the decision and to be fully informed when deciding whether to escalate the matter to AFCA. •Final outcome of the complaint, including details of any actions taken to resolve the complaint;
•Reasons for the outcome, if the complaint was rejected in part or in full, including details of findings and the basis of the decision; and •The complainant’s right to take the matter to AFCA and the contact details for AFCA.
•A written IDR response must always be provided if the complaint is about; •Hardship; or
•The complainant requests a written response.
6.Where escalation is need, AFCA to be contacted.
What is complaint?
A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.
We would not consider the following to be a complaint:
(a) employment-related complaint raised by a staff member; and
(b) comments made about the business where a response is not expected, such as:
(i) feedback provided in surveys; or
(ii) reports intended solely to bring a matter to your attention—for example, your social media page keeps crashing or a link on the website is not working.
A broader definition of complaints to include social media
The definition of a complaint has been expanded to include any notice of dissatisfaction. This means if a customer makes a complaint on your social media page(s), then it must be managed through your IDR process.
Social media complaints include channels or accounts that are owned or controlled by the ACL. You are required to respond to the complainant if they are identifiable and contactable.
Examples for acknowledging complaints.
Complaint raised by social media, acknowledged via social media:Thank you for your feedback, we have sent you a private message.
Private message:Thank you for providing your feedback. Please call <provide name and number> or provide contact details and we can call you.
Complaint raised via phone call, acknowledge via email (Simple): Dear (Customer), Complainant: Broker's business name: AFCA Case number (if applicable): Thank you for your time today.
As discussed, we will treat our phone call as a formal complaint. < Brokers business name > will have 30 days to attempt to resolve the complaint. In the interim, if you have any queries, please do not hesitate to contact me. Kind regards,
Complaint raised via phone call, acknowledge via email (detailed):
Dear (Customer), Complainant:
Brokers business name: AFCA Case number (if applicable): Thank you for your time today. As discussed, we will treat our phone call as a formal complaint.
If you can please provide following information to us: •A timeline of events •Evidence of all communication •Documentation relating to the loan application and the complaint •The outcome you are seeking from the Broker and a justification for the outcome sought. Once we have received the above information, we will commence our review of the complaint. You may be required to provide further information other than the items stipulated above.
You will be required to provide this information to us no later than close of business (date). If you cannot meet this time frame, please confirm immediately. < Brokers business name > will have 30 days to attempt to resolve the complaint.
In the interim, if you have any queries, please do not hesitate to contact me. Kind regards,
Examples for finalising complaints
1)Resolution letter (within IDR)
Dear (Complainant)
We refer to your conversation with us on (Date) where you lodged a formal complaint against (Broker details).
(Add ACL/ACR) has investigated all claims and evidence supplied to us by you and the Broker.
Having regard to the information provided, we summarise and address our understanding of your complaint as follows: •<Identify and address the issues raised in the complaint, refer to information that supports the findings.> In resolution of your complaint and as a goodwill gesture, the following further action has been agreed by all parties:
•<Outline steps taken to resolve complaint.> Please confirm your acceptance of the above resolution by countersigning this letter.
If you are not satisfied with our decision, you have the right to lodge a complaint with the Australian Financial Complaints Authority (AFCA). The AFCA scheme is a free service established to provide you with an independent mechanism to resolve specific complaints. I have provided AFCAs details below 1800 931 678 info@afca.org.au GPO Box 3, Melbourne, VIC 3001 Yours faithfully,
2) Rejection of complaint
Dear (Complainant),
We refer to your conversation with us on (Date) where you lodged a formal complaint against (Broker details). (Add ACL/ACR) has investigated all claims and evidence supplied to us by you and the Broker. Having regard to the information provided, we summarise and address our understanding of your complaint as follows: •<Identify and address the issues raised in the complaint, refer to information that supports the findings.> Reasons why we reject or partially reject the complaint
•<Outline the reasoning for rejecting the complaint, refer to information that supports the findings.> If you are not satisfied with our decision, you have the right to lodge a complaint with the Australian Financial Complaints Authority (AFCA). The AFCA scheme is a free service established to provide you with an independent mechanism to resolve specific complaints. I have provided AFCAs details below
1800 931 678 info@afca.org.au GPO Box 3, Melbourne, VIC 3001
6.Where escalation is need, AFCA to be contacted.
What is complaint?
A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.
We would not consider the following to be a complaint:
(a) employment-related complaint raised by a staff member; and
(b) comments made about the business where a response is not expected, such as:
(i) feedback provided in surveys; or
(ii) reports intended solely to bring a matter to your attention—for example, your social media page keeps crashing or a link on the website is not working.
A broader definition of complaints to include social media
The definition of a complaint has been expanded to include any notice of dissatisfaction. This means if a customer makes a complaint on your social media page(s), then it must be managed through your IDR process.
Social media complaints include channels or accounts that are owned or controlled by the ACL. You are required to respond to the complainant if they are identifiable and contactable.