• LeasePlan Australia

    (last update February 2023)

    PRIVACY POLICY

    1. Your rights in relation to privacy

    . LeasePlan Australia Limited ACN 006 923 011 (LeasePlan) is committed to providing the best possible leasing and fleet management services for its customers.  To provide these services, LeasePlan needs your personal information including your credit related personal information. LeasePlan understands the importance of protecting the privacy of an individual’s personal information. 

    This policy statement applies to the personal information of individuals who are our current or former customers, as well as any other individuals we may deal with as part of our business.  It sets out how LeasePlan aims to protect the privacy of your personal information, your rights in relation to your personal information managed by LeasePlan and the way LeasePlan collects, holds, uses and discloses your personal information.

    In handling your personal information, LeasePlan will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. To the extent LeasePlan handles your credit related personal information, LeasePlan will also comply with the Credit Reporting Code.
     
    2. What kinds of personal information does LeasePlan collect?

     Personal information is information or an opinion about an identified, or reasonably identifiable, individual.  During the provision of its services, LeasePlan may collect your personal information.

    Generally, the kinds of personal information LeasePlan collects are:

    • contact and identification information such as your name and previous names, address and previous addresses, telephone number, email address, date of birth, marital status, number of dependants, gender and driver’s licence details;
    • employment information such as your current and previous places of employment, occupation and job title, and payroll information;
    • financial information about your assets and liabilities, occupation and income, account balances, account activities, expenditures, payment history and transactions with us or third parties;
    • vehicle-related information such as location data, driver behaviour indicators and trip purposes, including for the provision of telematics services;
    • credit information, being credit-related personal information lawfully created and accessible within the Australian credit reporting system including:
                o consumer credit liability information which includes information about credit providers and credit accounts including the dates on which the accounts are opened and closed, their terms and conditions (or changes to the terms and conditions) and the maximum limit of credit available under an account;
               o information about your repayment history;
               o information about defaults and subsequent payments made;
               o information about other credit providers having sought credit-related information about you from a credit reporting body;

               o information about the types of consumer or commercial credit you have sought in an application;
               o information about court proceedings that relate to credit provided to you or for which you have applied;
               o personal insolvency information about you;
               o publicly available information relating to your credit worthiness;
               o information about a credit provider’s opinion that you have committed a serious credit infringement in relation to consumer credit provided by that credit provider to you;
               o any other information lawfully obtainable within the Australian credit reporting system;
    • credit eligibility information which is information about you that LeasePlan obtains from a credit reporting body, such as Equifax Information Services and Solutions Limited (Equifax)  (the details of which are set out in paragraph 5), together with information LeasePlan derives from such information based on its own analysis including through an internal scoring process to assess credit worthiness.  LeasePlan generally receives from Equifax information about your previous addresses, previous credit applications, previous defaults and any court judgments and bankruptcies;
    • where you are applying for a position within LeasePlan, proof of eligibility to work within Australia, proof of qualifications, and references;
    • sensitive information including:
        o health information:
        o where you consent to the collection of such information and if relevant to the provision of services (eg to assist your employer to comply with its occupational health and safety obligations in connection with your use of a vehicle); or
       o where you are applying for a position with LeasePlan and it is relevant to the recruitment process through which you must progress following your application to LeasePlan;
       o where you are applying for a position with LeasePlan, criminal record information where relevant to LeasePlan’s assessment of whether you are able to perform the inherent requirements of the particular role;
      o otherwise, criminal record information for insurance purposes; and
      o other information, such as driving, insurance and claims history, for insurance purposes.

    In some circumstances LeasePlan may also hold other personal information provided by you.
    3. How does LeasePlan collect personal information?
     Generally, LeasePlan collects your personal information directly from you, either through LeasePlan Online or manually through an interaction or exchange in person or by way of telephone, fax, email or post. There are also occasions when LeasePlan collects your personal information, including credit related personal information, from other sources such as from:
     
    • your employer, in the course of providing or seeking to provide vehicle leasing or fleet management services or otherwise to establish and manage your employer’s fleet of vehicles;
    • introducers and brokers;
    • Equifax or other credit reporting body;
    • another credit provider;
    • service providers including insurers, dealers, maintenance service providers, and roadside assistance providers;
    • an information services provider;
    • a publicly maintained record or other publicly available sources of information including social media and similar websites;
    • LeasePlan’s own records about you, from which LeasePlan may internally generate its own scores, assessments or deductions, particularly in relation to your credit worthiness;
    • if for recruitment purposes, an external recruitment or background screening services provider, and your referees.


    Generally, LeasePlan will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

     
    4. Why does LeasePlan need your personal information?
     LeasePlan collects, holds, uses and discloses your personal information, including credit related personal information, where it is reasonably necessary for the purposes of:
     
    • providing fleet management services to you or your employer;
    • conducting necessary fleet management operations and activities, including fleet reporting;
    • processing an application made by you;
    • identification purposes;
    • evaluating and monitoring your credit worthiness, including through internal credit scoring;
    • servicing your customer account, responding to queries by you or your employer and maintaining a relationship with you;
    • ensuring your vehicle is appropriately fitted and/or modified to suit any health or physical needs;
    • assisting your employer to comply with its work health and safety obligations;
    • conducting market research and/or customer satisfaction research;
    • facilitating and processing payments relating to you;
    • processing and administering, on behalf of your employer, an application for any salary sacrificing arrangement whether in connection with a novated lease arrangement or other employee benefit;
    • facilitating appropriate insurance cover and assessing, processing and investigating insurance risks and/or claims relating to you;
    • accounting, billing, record keeping, systems development testing, staff training and other internal administrative purposes;
    • identification, prevention and investigation of, and/or co-operation with relevant law enforcement bodies in relation to any criminal or fraudulent activity relating to you;
    • developing, establishing and administering business partnerships and other arrangements with other entities in relation to the promotion, administration and use of LeasePlan’s products and services;
    • using processes including market surveys and strategies and customer analytics to improve the development of LeasePlan’s products and services;
    • identifying and informing you of products and services that may be of interest to you from LeasePlan or selected third parties;
    • assessing your application for employment with LeasePlan or otherwise for the purposes of engaging you as a contractor or consultant;
    • any other legal or regulatory compliance requirements of LeasePlan.


    LeasePlan may also use your personal information for purposes related to the above and for which you would reasonably expect LeasePlan to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.

    Where personal information is used or disclosed, LeasePlan takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to LeasePlan.  However, without certain information from you, LeasePlan may not be able to provide its products and/or services to you or your employer.

    If, at any time, you provide us with the personal details of someone else (e.g. spouse), you must ensure that the person has read and understood this Privacy Policy and separately consented to his or her personal information being used and disclosed to us by you for the purposes detailed in this policy.

     
    5. To whom does LeasePlan disclose your personal information?

    LeasePlan discloses your personal information for the purposes for which LeasePlan collects it.  That is, generally, LeasePlan will only disclose your personal information for a purpose, or purposes, set out in paragraph 4.  This may include disclosing your personal information to:

    • third parties engaged to perform administrative or other services, including website hosting providers, IT system administrators, data storage providers, stationery printers and mailing houses;
    • third parties, as directed by you or your employer;
    • third parties, for the purpose of raising finance by way of a securitisation transaction;
    • people or entities considering acquiring an interest in LeasePlan’s enterprise or assets;
    • LeasePlan’s professional advisors, contractors, consultants, service providers and related bodies corporate;
    • insurance providers;
    • dealerships and other third parties who provide vehicle management services; and
    • regulatory bodies and government authorities including the Australian Taxation Office, relevant road traffic authorities, and other third parties such as toll road and car park operators.

    LeasePlan may also disclose your personal information, including your credit information, to lenders, other credit providers and the credit reporting body, Equifax (contactable on the details set out below). In particular, LeasePlan may disclose to Equifax information about you failing to meet your payment obligations or if you commit a serious credit infringement. Equifax may include any information provided by LeasePlan in reports provided to other credit providers for the purpose of such credit providers assessing your credit worthiness.  Such disclosures are always on a confidential basis or otherwise in accordance with law.  LeasePlan may also disclose your personal information with your consent or if disclosure is required or authorised by law.

    Equifax can be contacted by any of the following:
    Phone: 13 83 32
    Email:  www.equifax.com
    Post:  PO Box 964, North Sydney NSW 2059

    Equifax’s policy on its management of credit related personal information can be accessed through its website at: www.equifax.com.au/privacy
     
    6. Cross border disclosure

    LeasePlan may disclose personal information, including credit related personal information, to overseas recipients in order to provide its products and/or services, and for administrative, IT, data storage or other business management purposes including fleet reporting, or in circumstances where your employer’s mail servers are located overseas.  Recipients of such disclosures may include service providers located in the European Union.  Other recipients may be located in Singapore, the Philippines and India. 

    Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, LeasePlan takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.  If you have any queries or objections to such disclosures, please contact LeasePlan’s Local Privacy Officer on the details set out in paragraph 12.

    7. Direct marketing

    LeasePlan may use and disclose your personal information in order to inform you of products and services that may be of interest to you.  In the event you do not wish to receive such communications, you can opt-out by contacting LeasePlan via cservice@leaseplan.com.au  or through any opt-out mechanism contained in a marketing communication to you. 

    LeasePlan will not use or disclose credit-related personal information for direct marketing purposes except to the extent permitted under the Privacy Act, for the purpose of Equifax assessing your eligibility to receive direct marketing communications sent on behalf of LeasePlan. You may make a request directly to Equifax not to use your credit-related personal information for these purposes.

     
    8. Security of your personal information

    LeasePlan takes steps reasonable in the circumstances to ensure that the personal information, including credit related personal information, it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. 

    LeasePlan holds personal information in both hard copy and electronic forms in secure databases on secure premises (including through locks, firewalls, encryptions, log-ins and passwords, and other physical and network security measures as appropriate), accessible only by authorised staff.  Credit eligibility information, such as information LeasePlan receives from Equifax for the purpose of assessing credit worthiness, is stored through equally secure methods. Staff are bound by security policies and confidentiality agreements, which are regularly revised and re-issued. 

    LeasePlan will destroy or de-identify personal information (whether through shredding hardcopy documents or permanently deleting from its systems or de-identifying electronically-held information) in circumstances where it is no longer required, unless LeasePlan is otherwise required or authorised by law to retain the information.

    If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you may request Equifax not to use or disclose credit related personal information it holds about you by contacting Equifax on the details set out in paragraph 5.

     
    9. Website security and cookies

    The LeasePlan website uses session ‘cookies’ which are small pieces of information sent by our website and stored by your browser on your computer’s hard drive. A cookie can later be retrieved by our webpage servers. Cookies used by LeasePlan do not contain any of your personal information but enable us to recognise the number of times you access the LeasePlan website through your computer so that LeasePlan can tailor the information made available to you with the view to making your visit to the website easier, faster and more productive. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.

    LeasePlan uses Google Analytics which may also place cookies on your computer.  Please read its privacy policy to ensure that you are comfortable with the manner in which it uses cookies.

    LeasePlan uses Google Analytics features including Display Advertising, Remarketing, DoubleClick Campaign Manager integration and Google Analytics Demographics to collect data about traffic on its website, including the age and gender of its audience (where it is possible to ascertain this information), and to advertise online.  Third party vendors may show LeasePlan advertisements on sites across the Internet. LeasePlan and third party vendors may use cookies to understand more about how their websites are used and to display advertisements to you based on your past visits to LeasePlan’s, or the third party’s, websites.

    However, LeasePlan does not use any information obtained through the use of Google Analytics, or cookies, to identify any individual user of its website.

    If you wish, you can opt-out of Display Advertising and customize Google Display network advertisements by using the Ads Settings feature in your browser.
    10. Can you access and correct the personal information that LeasePlan holds about you?

    LeasePlan takes steps reasonable in the circumstances to ensure the personal information it holds, including your credit related personal information, is accurate, up-to-date, complete, relevant and not misleading.  Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by LeasePlan. 

    LeasePlan will grant access to your personal information to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct your personal information where necessary and appropriate. Where necessary to resolve a request for correction of your credit related personal information, LeasePlan may also consult with other relevant entities, including but not limited to Equifax.  LeasePlan’s use or disclosure of your credit related personal information to other entities for correction purposes is permitted by the Privacy Act.

    If at any time you would like to access or correct the personal information that LeasePlan holds about you please contact the person, or department that you normally deal with to request access or correct your personal information.  To obtain access to your personal information:

    • you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
    • LeasePlan requests that you be reasonably specific about the information you require; and
    • LeasePlan may charge you a reasonable administration fee, which reflects the cost to LeasePlan, for providing access in accordance with your request.

    Alternatively, if you would like to access personal information held about you by Equifax, please contact Equifax on the contact details set out in paragraph 5.

    LeasePlan will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If LeasePlan refuses your request to access or correct your personal information, LeasePlan will provide you with written reasons for the refusal and details of complaint mechanisms. For example, we may need to decline access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. LeasePlan will nevertheless take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of LeasePlan.

    If you are dissatisfied with LeasePlan’s refusal to grant access to, or correct, your credit related personal information, you may make a complaint to the Office of the Australian Information Commissioner.
    11. How to contact us

    For further information or enquiries regarding your personal information please contact the person or department that you normally deal with.

    12. Privacy Complaints

    Please direct all privacy complaints to LeasePlan’s Local Privacy Officer by writing to:

    Local Privacy Officer
    LeasePlan Australia Limited
    P O Box 6297
    St Kilda Road Central, Victoria, 3004
    privacy-officer@leaseplan.com.au

    At all times, privacy complaints:


    • will be treated seriously;
    • will be dealt with promptly;
    • will be dealt with in a confidential manner; and
    • will not affect your existing obligations or affect the commercial arrangements between you and LeasePlan.

    Specifically, if your complaint relates to credit related personal information and/or LeasePlan’s failure to comply with its obligations regarding credit related personal information under the Privacy Act and/or the Credit Reporting Code;
    • LeasePlan will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless LeasePlan informs you otherwise and seeks your agreement in writing;
    • LeasePlan may consult with relevant third parties, such as Equifax or other credit provider, in order to sufficiently and expeditiously resolve the complaint; and
    • if your complaint relates to LeasePlan’s refusal to provide access to, or correct, your credit related personal information, you may complain directly to the Office of the Australian Information Commissioner.

    LeasePlan’s Local Privacy Officer will commence an investigation into any complaint made by you to LeasePlan.  You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint or an extension to the time in which LeasePlan will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.
    13. Changes to our Privacy Policy 

    From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. All personal information held by us will be governed by the current Privacy Policy published on our website.