Credit Reporting Policy (Consumer Finance)

Automated Collection Services Pty Ltd ACN 144 738 796 trading as ACS Asset
(and our related businesses)

Purpose

This Credit Reporting Policy explains how we manage credit information and credit eligibility information in accordance with:

  • Part IIIA of the Privacy Act 1988 (Cth)
  • the Privacy (Credit Reporting) Code 2025 (CR Code)
  • applicable consumer credit and regulatory obligations

This Policy applies to our consumer finance products and credit-related activities.

Our role and responsibility

Automated Collection Services Pty Ltd (ACN 144 738 796), trading as ACS Asset Management, holds Australian Credit Licence 468425 and is a member of the Australian Financial Complaints Authority (AFCA membership number 45722).

We act in two capacities:

  • As a credit provider. For products or programs where ACS is the lender, we are the credit provider, and this Policy sets out how we manage your credit information.
  • As a service provider for other lenders. We process applications, service loans, manage collections and carry out credit reporting tasks on behalf of other lenders, including Smile Right Capital Pty Ltd (Smile Right), Breeze Capital Pty Ltd (Breeze Finance) and Pay for Paws Capital Pty Ltd (Pay for Paws). For these loans, the lender is the credit provider and remains responsible for credit reporting under the Privacy Act 1988 (Cth). Its own credit reporting policy applies, and you can make access, correction or complaint requests to the lender or to us.

Because of system and character limits, a credit enquiry or account made through us for another lender may show "Automated Collection Services" on your Equifax credit report. This does not mean you owe us money or have an account with us.

Scope

This Policy applies to:

  • applicants for consumer credit
  • current and former consumer credit customers
  • credit information we obtain from or disclose to credit reporting bodies
  • credit reporting information we hold or use in connection with consumer finance

Types of Credit Information We Handle

We may collect, hold, use and disclose the following credit-related information:

  • identification information
  • credit application information and enquiries
  • consumer credit liability information
  • repayment history information (RHI)
  • default information (where permitted under law)
  • hardship arrangement information (where applicable and permitted)
  • credit eligibility information received from credit reporting bodies
  • information derived from credit reporting data
  • fraud prevention and identity verification information

We only collect and use credit information that is reasonably necessary for our consumer lending functions.

Sources of Credit Information

We obtain credit information from:

  • Equifax, the credit reporting body we use
  • credit applications and supporting documentation provided by you
  • internal account and repayment systems
  • identity verification and fraud prevention services
  • other credit providers (where permitted by law)

Use of Credit Information

We use credit information to:

  • assess consumer credit applications
  • verify identity and prevent fraud
  • manage existing credit accounts
  • monitor repayment performance
  • meet legal and regulatory obligations
  • comply with credit reporting obligations under Part IIIA

Some of this assessment is carried out by automated systems. See "Automated decisions" in our Privacy Policy.

We do not use credit information for unrelated purposes.

Disclosure of Credit Information

We may disclose credit information to:

  • Equifax, the credit reporting body we use
  • service providers assisting with credit assessment or account management
  • other credit providers (where permitted by law)
  • internal staff and authorised representatives
  • professional advisers (legal, accounting, compliance)
  • regulators or law enforcement where required or authorised by law
  • entities involved in sale, assignment or transfer of finance assets or business operations

We take reasonable steps to ensure disclosures are made in accordance with applicable legal requirements.

Credit Reporting Body

We exchange credit information with one credit reporting body:

Equifax Pty Ltd Website: www.equifax.com.au Postal: GPO Box 964, North Sydney NSW 2059 Phone: 13 8332

Equifax's credit reporting policy, which explains how it manages credit reporting information, is available on its website.

Equifax may use credit information to:

  • maintain credit reports
  • provide credit reporting services to other credit providers
  • support fraud prevention and credit assessment, as permitted by law

Accuracy and Data Quality

We take reasonable steps to ensure that credit information we report is:

  • accurate
  • up-to-date
  • complete
  • relevant
  • not misleading

Our controls include:

  • validation of account and repayment data prior to reporting
  • review of account status before reporting defaults
  • internal reconciliation processes
  • investigation of discrepancies raised by customers or credit reporting bodies

Where we identify incorrect information, we take reasonable steps to correct it.

Access to Credit Information

You may request access to credit information we hold about you.

We will:

  • verify your identity
  • respond within a reasonable period in accordance with legal requirements
  • provide access unless a legal exception applies

Requests should be made using the contact details in this Policy.

Your rights regarding credit enquiries and credit reporting

When we make a credit enquiry about you that we are likely to disclose to Equifax, your consent is not required for that disclosure. A record of the enquiry may be used to help calculate your credit score or rating. Enquiries are one of the factors a credit reporting body may take into account.

You can ask Equifax not to use your credit reporting information for pre-screening of direct marketing by a credit provider.

If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you can ask Equifax not to use or disclose your credit reporting information. This is called a ban period. Equifax will notify the other credit reporting bodies, so you only need to make the request once.

These requests are made directly to Equifax, not to us. Contact Equifax at www.equifax.com.au.

Correction of Credit Information

You may request correction of credit information you believe is:

  • inaccurate
  • out-of-date
  • incomplete
  • irrelevant
  • misleading

Our process:

Upon receiving a correction request, we will:

  1. acknowledge receipt of the request
  2. verify identity
  3. investigate the information in question
  4. review internal records and relevant supporting information
  5. consult with relevant credit reporting bodies where required
  6. determine whether correction is required

Timeframes:

We will respond within the timeframes required under:

  • Part IIIA of the Privacy Act 1988 (Cth)
  • the Privacy (Credit Reporting) Code 2025 (generally within 30 days unless extended as permitted)

If correction is required:

We will take reasonable steps to:

  • correct our records
  • notify relevant credit reporting bodies
  • ensure updated information is reflected where required

Credit Reporting Complaints and Disputes

If you believe credit information we hold is incorrect or has been improperly handled, you may lodge a complaint with us.

We will:

  • investigate your complaint in accordance with this Policy
  • review internal records and supporting documentation
  • consult credit reporting bodies where required
  • keep you informed of progress
  • provide a written outcome with reasons

Defaults and Consumer Credit Reporting

We may report default information to credit reporting bodies where permitted under law.

We take reasonable steps to ensure:

  • the debt is valid and payable
  • required notices have been issued (where applicable)
  • default amounts are accurate
  • updates or removals are made where required

Where a default is disputed, we will investigate and take appropriate action under this Policy.

Hardship Information

Where applicable, we may record hardship arrangements in accordance with the Privacy Act and CR Code.

We ensure hardship information is:

  • accurately recorded
  • kept up to date
  • corrected where arrangements change or conclude
  • handled in accordance with legal requirements

Security of Credit Information

We take reasonable steps to protect credit information from:

  • misuse
  • interference
  • loss
  • unauthorised access, modification or disclosure

Safeguards include access controls, staff confidentiality obligations, encryption where appropriate, and system security protections.

Retention and Destruction

We retain credit information only for as long as necessary to:

  • manage credit relationships
  • comply with legal obligations
  • meet credit reporting requirements

When no longer required, we take reasonable steps to securely destroy or de-identify the information.

Where credit information is stored

We store credit information in Australia. We do not disclose credit reports, or credit eligibility information obtained from Equifax, to anyone outside Australia.

Some of our service providers store limited information about your credit account in the United States:

  • SMS messages we send you, which may include account and repayment information, such as a payment reminder or an overdue amount
  • documents you sign electronically, such as a change to your nominated bank account or an agreement to vary your loan contract. These may include your loan terms and the terms of any variation.

We take reasonable steps to ensure these providers handle the information in line with the Australian Privacy Principles, as explained in our Privacy Policy.

Relationship with Privacy Policy

This Credit Reporting Policy should be read together with our Privacy Policy.

In the event of any inconsistency, this Policy prevails to the extent of credit reporting information.

Availability of this Policy

This Policy is available on our website or upon request.

Contact Us

Privacy Officer

ACS Asset Management

PO Box 7795, Cloisters Square WA 6850

Alternatively you can call us on 1300 851 953 or email privacy@acsasset.com.au

Review of Policy

We review this Policy periodically to ensure ongoing compliance with:

  • the Privacy Act 1988 (Cth)
  • the Privacy (Credit Reporting) Code 2025
  • applicable regulatory guidance