Privacy Policy

Milton Graham is a trading name and part of the illion group of companies that provides various services involving personal information including Receivables Optimisation:

To simplify matters Milton Graham is referred to as “us” “we” and “our” in this policy.

Milton Graham recognises the importance of protecting information including the special protection of Personal Information.

By using our Receivables Optimisation products or services you agree to be bound by this Privacy Policy.

If the Personal Information was provided to us by another party, we will have sought their confirmation that it was authorised for them to provide us with that Personal Information in accordance with this Privacy Policy and that they informed the individual of their rights to access and request correction of the Personal Information, as set out below.

We may update our Privacy Policy from time to time to reflect changes to applicable law or changes to our business practices. The updated Privacy Policy will be published on this website and the updated policy will apply to all Personal Information held from that time onwards.

The personal information we collect from or about individuals, is the information that is reasonably necessary for our business purposes, including providing receivables optimisation services to our customers. We may collect a range of personal information from or about an individual including their:

• name;
• date of birth;
• driver’s licence number;
• marital status;
• gender;
• phone number/s;
• email address/es;
• residential / business / postal address;
• residence type;
• employment history;
• income;
• assets;
• liabilities;
• banking or other financial transaction data; and
• credit information, including repayment information.

We will only collect sensitive information (such as race, religion, ethnicity, health information, criminal record, sexual orientation, trade union memberships etc.) if we (or our customer) has been given express consent to do so, and:

• the information is reasonably necessary for us to carry out our functions or activities;
• the use of the information is required or authorised under an Australian law, court or tribunal order.

We might, in limited circumstances, utilise biometric information for identification verification purposes but will only do so when expressly authorised by the individual concerned.

The information we collect is predominantly in a digital format. The collection of information may include the combining of differing data points about individuals to form a more complete record of the information illion holds, this may also allow it to present information in a readily usable format.

We collect information from our customers, individuals directly, third party service/data providers, Court records, publicly accessible databases and or authorised parties.

We also may collect Personal Information about our customers, or employees or officers’ of our customers and prospective job applicants, so that we can meet internal operational requirements, complete business transactions, conduct research, deliver products and services, administer accounts, provide customer support or meet regulatory requirements.

We are serious about the security of the information we collect. To protect this information we employ contractual and administrative steps to ensure that this information is protected against any unauthorised access, disclosure or misuse. In addition to this we also utilise significant technology solutions to protect against unauthorised access or disclosure.

All our employees undertake training in handling information, with particular emphasis on preserving the personal information of individuals. We limit physical and digital access to our premises and computer networks to those that require such access.

We collect, hold, use and disclose Personal Information in order to operate our business, including providing services to our customers and individuals. Some of the most common purposes for this will be:

• assisting our customers in debt management and debt recovery;
• assisting individuals and businesses in understanding their credit worthiness;
• for identity verification purposes for individuals and businesses;
• managing our relationship with individuals and our customers;
• ensuring Personal Information is accurate and up to date;
• updating a credit reporting bureau in relation to defaults and or payments;
• assisting our customers in risk management;
• progressing debt recovery through the court litigation process including engaging legal representation as necessary;
• for analytics, product development, research and benchmarking;
• for audit and record keeping purposes and to comply with our legal and regulatory obligations;
• sharing with our group companies to assist with the management of information or delivery of our services; and
• and processing and managing applications to work with us.

While this list is not exhaustive, any purposes outside of this list will be consistent with those permitted under privacy laws.

Under privacy laws, an individual has the right to access and request correction of any Personal Information we hold about them. We also recognise the accuracy of the Personal Information we hold about an individual is critical to our business so encourage individuals to correct any errors where they exist.

To access Personal Information please use the following contact point:

Australia & New Zealand
E-mail: enquiries@miltongraham.com.au

While we take reasonable steps to ensure that the Personal Information held by us is accurate and up to date, we generally rely on our customers, data suppliers and individuals to inform us if the information we hold is inaccurate or incomplete.

Once Personal Information is provided it is important that any errors are corrected, these should be raised through the Public Access Centre on the details above.

While we aim to address matters quickly and efficiently we understand there are times when things may go wrong and an individual may want to make a complaint.

To make a complaint it may be beneficial to complete the online form (located here) to ensure all relevant information is available. Alternatively it may be helpful to complete a Complaint lodgment Form (located here) and return it to:

Australia
Attention: Privacy Complaints Company: illion Australia
Postal Address: PO Box 7405
St Kilda Rd Melbourne VIC 3004 Email: chc-au@illion.com.au
Fax: (03) 9828 3118

New Zealand
Attention: Privacy Complaints Company: illion New Zealand
Postal Address: PO Box 9589 Newmarket, Auckland 1031 Email: chc-nz@illion.co.nz
Fax: (09) 309 2050

As per our complaint handling policy we will address complaints as quickly and efficiently as possible, at a minimum we will acknowledge receipt of a complaint within five business days and commit to investigating the complaint and providing a response within 30 days, provided that we have access to all necessary information. In cases where further information, assessment or investigation is required, we will seek to agree on an acceptable alternate time frame.

If a privacy related complaint continues to be unresolved there may be the option to escalate the matter to an external body, this could be to the:

• Office of the Australian Information Commissioner (Australia) or
• Office of the Privacy Commissioner (New Zealand).

Our businesses operate across Australia and New Zealand. Australian and New Zealand privacy laws are substantially similar. If we disclose information to related companies as part of our internal operations, we will comply with Australian law in respect of Australian information and New Zealand law in respect of New Zealand information.

While our customers are generally local entities they may have operations overseas, this means we are unaware of what information our customers may disclose overseas. It is not possible to identify other countries where our customers might allow their information to be disclosed to.

In supplying our services we may utilise service providers, resources, and cloud based processes located outside of Australia or New Zealand. We use reputable service providers and ensure they have appropriate controls and contractual obligations relating to security of data.

We may use technology known as a “cookie” to collect statistical information about you when you visit the illion Site or use any of our products or services. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the illion Site, allowing it to remember you the next time you visit and provide a more meaningful experience.

You can switch off cookies by adjusting the settings on your web browser. If you disable the use of cookies on your web browser or remove or reject specific cookies from the illion Site then you may not be able to gain access to all of the content and facilities on the illion Site.

From time to time we may collect, use, store and disclose non-identifiable information relating to your use of the illion Site or any our websites or any of our products or services. For example, we may record information such as the areas of the illion Site that you visit along with the time, date and URL of the pages you access, the device you access the illion Site from, your IP address and/or the previous website that you visited before linking to the illion Site. We normally use this information in the aggregate to administer and improve our web site, and monitor proper website usage.

We may allow our service providers to also use cookies on our Site to track performance and to advertise products and services elsewhere on the Internet.

The Personal Information provided by our customers (or individuals directly) for this service is not used for Direct Marketing.

Last updated January 2021