Privacy Policy
Our Privacy Obligations
Commercial Credit Services Pty Limited is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). The APPs regulate how personal information is collected, stored, used and disclosed by Commercial Credit Services Pty Limited.
‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable. This includes names, contact details, financial information, and details relating to outstanding debts or credit history. Commercial Credit Services Pty Limited’s Privacy Policy applies to personal information collected and/or held by us.
Additionally, as an organisation operating in NSW that collects, holds or uses health information, Commercial Credit Services Pty Limited is also governed by the Health Records & Information Privacy Act 2002 (NSW).
Additionally, as an organisation operating in Victoria that collects, holds or uses health information, Commercial Credit Services Pty Limited is also governed by the Health Records Act 2001 (VIC).
We will review this policy regularly, and we may update it from time to time to reflect changes in our operations or legal obligations.
The Types of Personal Information We Collect and Hold
We collect personal information as part of our routine debt collection and business operations. This includes information about individuals who owe debts (debtors), guarantors, individuals acting on behalf of businesses, and other associated persons.
We collect personal information about our customers (the businesses and organisations that engage our services).
We also collect personal information about our staff, contractors and suppliers, as well as the contact details of individuals who work for contractors and suppliers, and other types of professional associates and personal contacts.
Types of personal information we collect may include:
• Full name
• Date of birth
• Gender
• Company name or business name and details
• Residential and postal addresses
• Email address
• Telephone and mobile numbers
• Employment details (e.g. employer name, occupation, work address)
• Financial information (e.g. income, assets, liabilities, expenses)
• Bank account or payment details
• Credit information and credit eligibility information (as defined under the Privacy Act)
• Details of debts owed (including original creditor, amount, due dates, and payment history)
• Repayment arrangements and financial hardship information
• Government-issued identification details (e.g. driver’s licence number, Medicare number.)
• Legal information (e.g. court judgments, bankruptcy status, or insolvency details)
• Communication records (including call recordings, emails, letters, and notes of interactions)
• Authorised representative or legal guardian information (if applicable)
• Any other personal information provided to us directly or indirectly that is reasonably necessary for, or directly related to, our debt collection functions and activities
How We Collect Personal Information
We collect personal information in a number of ways, depending on how you engage with us.
Information That You Specifically Give Us
We may collect personal information directly from you when you:
• Contact us by phone, email, mail or in person
• Speak with our representatives over the phone
• Provide information through a form, website or payment portal
• Authorise a representative (e.g. financial counsellor) to speak on your behalf
• Respond to a request for information
• Provide documentation for identification or verification
• Make a payment or enter a repayment arrangement
You may also provide personal information without being asked — for example, when posting on our social media or sending an unsolicited email.
Information that we collect from others
In our role as a debt collection agency, we often collect personal information about individuals from third parties, including:
• Our clients - Original creditors (e.g. financial institutions, utility companies, lenders, service providers)
• Credit reporting bodies
• Referees, guarantors, or authorised third parties
• Publicly available Sources (e.g. ASIC, court records, social media)
• Financial counsellors, legal representatives or authorised agents
• Other third-party providers
We only collect this information where it is necessary for our legitimate functions or required by law.
When you apply for a job or contract with us, we collect personal information from your referees. With your consent, we may also use third-party services to verify your employment history, education, and identity records. Police checks may be conducted to meet legal, regulatory, or client requirements for roles involving sensitive or secure environments. We may also verify supplier details using publicly available sources such as the Australian Business Register and ASIC databases.
Information that we generate ourselves
As part of our operations, we generate and maintain records relating to our interactions with clients and their customers. This includes information about debt collection services we have provided, communications with debtors and any actions taken throughout the recovery process. These records help us deliver effective service and ensure compliance with relevant legal and regulatory obligations.
Examples of information we generate ourselves include:
• Contact history and notes of phone calls
• Records of repayment agreements or settlements
• Details of payments made and outstanding balances
• Complaints and dispute history
• Internal assessments or categorisation of account status (e.g. risk ratings)
We collect limited information about users of our websites, for diagnostic and analytic purposes. We use cookies and gather IP addresses to do so, but we do not trace these back to individual users.
Links to other sites
On our website, we may provide links to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.
How We Use Personal Information
We use personal information only where necessary to carry out our functions as a debt collection agency and to comply with legal obligations. The way we use personal information depends on our relationship with the individual or organisation.
1. For Debtors (Individuals with Debts Referred to Us)
We use personal information to:
• Contact you about an outstanding debt referred to us
• Verify your identity and relationship to the debt
• Confirm the legitimacy of a debt or investigate disputes
• Assess your financial situation, including hardship circumstances
• Establish, manage, or review repayment arrangements
• Receive and allocate payments
• Provide access to payment platforms or communicate about account status
• Maintain accurate and updated records of interactions and outcomes
• Comply with regulatory obligations or respond to lawful requests
• Take legal or enforcement action, where appropriate
2. For Clients (Businesses or Organisations That Engage Us)
We use personal information of our clients and their representatives to:
• Provide debt collection and recovery services
• Communicate about account placement, progress, and results
• Report on collections activity and outcomes
• Comply with contractual obligations and service levels
• Issue invoices, manage accounts, and process payments
• Respond to client enquiries or complaints
• Maintain a record of communications and service history
• Develop, improve, or tailor our services to client needs
3. For Others (Staff, Contractors, Suppliers, and Other Contacts)
We use personal information of other individuals we interact with to:
• Manage employment, contractor, or supplier relationships
• Process payments to or from individuals or service providers
• Perform background checks where required
• Provide system access or manage user credentials
• Communicate with professional contacts or regulatory bodies
• Maintain internal records, systems, and legal compliance
• Conduct audits, training, or quality assurance activities
We do not use your personal information for direct marketing unless you have explicitly agreed to receive such communications (e.g. regarding repayment assistance or financial wellbeing services).
When We Disclose Personal Information
Our third-party service providers
The personal information of clients, debtors, staff, suppliers and other contacts may be held on our behalf outside Australia, including ‘in the cloud’, by our third-party service providers. This may include cloud-based platforms we use for debt management systems, customer communication, payment processing, data storage and client reporting. Our third-party service providers are bound by contract to only use your personal information on our behalf, under our instructions, and only for the purpose of assisting us in carrying our debt collection and related business operations in a secure and compliant manner.
Our service providers may include (but are not limited to):
• Microsoft Office 365 (cloud-based document and communication services)
• Xero (accounting)
• St.George Payway (online payments system)
• Debtsmart (Debtor Record Management system)
• Hubspot (CRM system)
• Mailchimp (email communications)
Other Disclosures and Transfers
We may also disclose personal information to third parties where necessary to support our debt collection activities and fulfil our legal and contractual obligations. These disclosures are made strictly in accordance with applicable privacy laws and only for legitimate and authorised purposes.
For Debtors:
We may disclose personal information about debtors to third parties for the following purposes:
• To our clients (the original credit providers or account holders) to report on the progress of collection activity or compliance with service agreements.
• To credit reporting bodies, where authorised by law, for the purpose of listing default information or updating credit status.
• To authorised legal representatives, law firms, courts or tribunals where legal proceedings are initiated or contemplated.
• To payment processing providers to facilitate debt repayment arrangements
securely.
• To investigators, field agents, or tracing agents engaged to locate individuals or verify information, where permitted by law.
• To regulatory or law enforcement authorities where required or permitted by law, including where fraud, identity theft or criminal activity is suspected.
For Clients:
We may disclose personal information provided by our clients to:
• Our internal staff and business systems to carry out collection services on behalf of the client.
• Our contracted service providers (such as cloud-based systems or mailing
providers) solely for the purpose of delivering services as instructed by the client.
• Legal and compliance advisers if a dispute arises in relation to our services or contractual obligations.
For Contractors and Other Third Parties:
We may disclose personal information to third parties engaged by us, including:
• IT and cloud service providers who host our systems, applications, or communication platforms.
• Auditors, accountants or compliance consultants who review our operations.
• Training and quality assurance partners for the purpose of improving service delivery and regulatory compliance.
• Phone & SMS providers e.g. to conduct phone calls, send SMS
In all cases, we take reasonable steps to ensure that third parties are contractually bound to handle personal information securely and only for the authorised purposes for which it was disclosed. Where information is transferred outside Australia, we ensure appropriate safeguards are in place, as required by the Privacy Act 1988 (Cth).
Security of Your Personal Information
We will take reasonable security measures to protect personal information from loss, unauthorised access, use, modification or disclosure.
Security measures include:
• Secure cloud storage with encrypted data
• Internal access controls and role-based permissions
• Firewall and antivirus protection
• Staff training on privacy and data security obligations
We will take reasonable steps to ensure personal information is stored securely, not kept longer than necessary to fulfil our debt collection obligations and comply with legal requirements. After this period, data is securely destroyed or anonymised.
Accessing or Correcting Your Personal Information
You have the right to request access to the personal information Commercial Credit Services Pty Limited holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable period for no charge.
You also have the right to request the correction of the personal information we hold about you. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up to date. Unless an exception applies, we must update, correct, amend or delete the personal information we hold about you within a reasonable time.
We do not charge for making corrections.
To seek access to, or correction of, your personal information, please contact our Privacy Officer via email privacy@customerreminder.com.au.
Automated Decisions
Commercial Credit Services Pty Limited does not make decisions that significantly affect individuals solely based on automated processes or algorithms. All decisions regarding debt recovery actions involve human review and discretion.
Exercising your other rights
You have a number of other rights in relation to the personal data Commercial Credit Services Pty Limited holds about you. You have the right to: opt-out of direct marketing, and profiling for marketing opt-out of processing for research / statistical purposes, or processing on the grounds of ‘public interest’ or 'legitimate interest’ erasure data portability, and temporary restriction of processing.
To Contact Our Privacy Officer
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
Email: privacy@boostcollections.com.au
Mail: PO BOX 453 Blacktown NSW 2148
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days.
If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by calling them on 1300 363 992, making a complaint online at www.oaic.gov.au, or writing to them at OAIC, GPO Box 5218, Sydney NSW 2001.