Principled Mortgage Investments Ltd (“the Company”) is committed to ensuring the privacy of its stakeholders is protected and managed in a manner consistent with the Australian Privacy Principles. The Company that personal information needs to be collected and handled with care and responsibility. This policy sets out how we manage personal information and safeguard the privacy of our stakeholders.
Definitions
Borrowing Parties includes Borrowers, Mortgagors, Guarantors and their related parties
Company means Principled Mortgage Investments Ltd, its related entities and staff
Personal Information has the same meaning as defined in the Privacy Act 1988 (Cth)
SCO means the Senior Compliance Officer
Kinds of Personal Information collected by the Company
The Company collects the following types of information from Borrowing Parties:
- (a) Full names, addresses, contact telephone numbers and email addresses;
- (b) Identification documents (drivers licenses, passports);
- (c) Credit history searches;
- (d) Personal banking details;
- (e) Corporate structures and employment histories;
- (f) Statements of financial affairs, including lists of assets and liabilities, income sources and expenditure.
The Company collects the following types of information from Investors:
- (a) Full names, addresses, contact telephone numbers and email addresses;
- (b) Tax File Numbers;
- (c) Identification documents (drivers licenses, passports);
- (d) Bank account details;
- (e) Investment histories;
- (f) Supporting documents, such as Trust Deeds.
How is Personal Information Collected
The Personal Information for Borrowing Parties is collected during the due diligence process, by:
- (a) requiring the borrowing parties to produce the information;
- (b) undertaking searches of public registers;
- (c) searching credit agency records, subject to the consent of the relevant person;
- (d) undertaking enquiries with service providers of the person subject to due diligence.
The Personal Information for Investors is collected by:
- (a) obtaining data on or with application forms;
- (b) requesting the investor to provide further information;
- (c) verifying data in accordance with the Anti Money Laundering and Counter Terrorism Financing Act (“AMLCTF Act”).
How is Personal Information held
All Personal Information is held in a combination of hard and electronic storage mediums at the office of the Company. Electronic data is backed up and stored off site.
Clients that provide personal information are required to advise the Company if their personal information has changed.
The Company has a range of security procedures in place to ensure the personal information collected is secure and protected from interference or unauthorised access.
Purposes Personal Information is collected, held, used
Borrowing Parties Personal Information is collected and used for:
- (a) assessing and reviewing credit applications;
- (b) managing ongoing loans;
- (c) conducting the administrative requirements of the Funds
- (d) meeting the requirements of the AMLCTF Act and the Corporations Act.
Investors’ Personal Information is collected and used for:
- (a) managing Investors investments in the Funds;
- (b) conducting the administrative requirements of the Funds;
- (c) meeting the requirements of the AMLCTF Act and the Corporations Act.
Circumstances where Personal Information is disclosed
The Personal Information of Borrowing Parties is disclosed in the following circumstances:
- (a) To service providers of the Company, such as lawyers preparing the security documents or valuers in relation to the security property assessment;
- (b) To Investors for the purposes of allowing Investors to assess whether they will participate in a mortgage loan investment;
- (c) To statutory bodies as required by law (such as ASIC or the Land Titles Office);
- (d) Where directed to by a Court.
The Personal Information of Investors is disclosed in the following circumstances:
- (a) To service providers of the Company, such as auditors, accountants and Compliance Committee members;
- (b) To statutory bodies as required by law (such as the ATO);
- (c) Where directed to by a Court.
How an individual may access and seek correction of their Personal Information
All individuals that have Personal Information about them held by the Company may request access to and seek correction of that Personal Information. Individuals in this situation should apply to the SCO as follows:
Senior Compliance Officer
Principled Mortgage Investments Ltd
PO Box 1347
Camberwell VIC 3124
Ph: 03 8803 6120
Email: admin@principled.com.au
The SCO will review the request and provide a written response to the applicant within a reasonable period.
Privacy concerns or complaints
If an individual has a concern or a complaint regarding the privacy of any Personal Information, whether the complaint is in relation to the Company or one of its service providers, the individual must contact the SCO at the contact details above. The SCO will provide details of our internal dispute resolution system, assess the complaint in consultation with the Managing Director and advise the outcome of the complaint in writing.
If the individual remains dissatisfied, the individual may then:
- (a) Refer the complaint to the Australian Financial Complaints Authority free of charge:
Web: www.afca.org.au
Mail: GPO Box 3 Melbourne VIC 3001
Phone: 1800 931 678
Email: info@afca.org.au - (b) Refer the complaint to the Office of the Australian Information Commissioner:
Web: www.oaic.gov.au
Mail: GPO Box 5218 SYDNEY NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au