document: title: privacy
text: At ING DIRECT, we're committed to ensuring the confidentiality and security of your personal information. We are bound by the Privacy Act 1988, including the Australian Privacy Principles (APPs) set out in that Act, to guide us in our responsible handling of your personal information.

This Privacy Statement provides an overview of the key aspects of our Privacy Policy.

To view the complete ING DIRECT Privacy Policy click here. You can also request a copy by either calling or writing to us.

Both this Privacy Statement and the complete Privacy Policy were last updated in March 2014.

### Collection

Ordinarily, we'll collect most personal information about you directly from you.

Occasionally we may need to obtain personal information about you from a third party, but only if you've consented to us collecting the information in this way or you would reasonably expect us to collect the information about you in this way.

We'll collect personal information to provide you with information about a financial product or service; to assess your application and eligibility for a financial product or service; to provide you with the financial products and services that you've requested; to administer our relationship with you; and to communicate with you about ING DIRECT and the products and services we offer, and then only when it's necessary for, or related to, these purposes.

We'll also need to collect personal information necessary to comply with Australian and global legal or regulatory requirements that have extraterritorial application to ING DIRECT or the ING Group. For example, ING DIRECT has an obligation to identify customers for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

If you don't provide the personal information that we request, we will generally not be able to provide you with ING DIRECT products or services.

### Use and Disclosure of your personal information

The general rule is that we will not use or disclose your personal information other than for the purposes stated at the time of the collection. If we want to use your personal information for another purpose, we will seek further consent from you, unless that other purpose is related to one of the original purposes of collection and you would reasonably expect us to use your personal information for that other purpose.

It may be necessary for ING DIRECT to disclose your personal information to certain third parties in order to assist us in providing, managing and administering your products or services or for other purposes related to our business - these third parties are specified in our Privacy Policy and we'll also let you know who they are at the time we collect your personal information.

Personal information will only be disclosed to third parties other than those we've specifically identified if you have consented to the disclosure; if you would reasonably expect us to disclose information of that kind to those third parties; if we are authorised or required to do so by law; or it is necessary to assist with law enforcement.

We may have to send personal information overseas, for example, if required to complete a transaction or where we outsource a function to an overseas contractor. Your personal information may be disclosed to staff in ING Group entities in Singapore and the Netherlands if necessary to administer our relationship with you; if those entities provide services to, or functions for, ING DIRECT; for transactional reasons; or to comply with Australian and global regulatory requirements applying to us or the ING Group (including to comply with requests for information received by overseas regulators).

### Marketing

We, or other ING Group entities, may provide you with further information about ING Group products and services unless you tell us not to.

If you have provided an email address to us, we may contact you using that email address, including to provide you with information about ING DIRECT and the products and services that we and the ING Group offer. You may elect not to receive further information about us or our products and services by contacting us online, calling or writing to us.

Our Social Media User Terms apply to your use of ING DIRECT's social media sites or facilities. If you engage with us on any of our social media channels, you agree to be bound by these terms.

### Lender's Mortgage Insurance

We may disclose personal information (including credit-related personal information) to the lender's mortgage insurer (LMI) listed below.

The LMI may use, hold and disclose to third parties any personal information it collects about you from us or credit reporting bodies in order to assess whether to insure the risk of providing mortgage insurance; to assess the risk of default; to assess the risk of a guarantor being unable to meet a liability arising under a guarantee; to administer and vary the insurance cover, including for securitisation and hardship applications; to verify information that we collect about you; to deal with claims and recovery of proceeds including, among other things, to enforce a loan in place of a lender if the mortgage insurer pays out an insurance claim on your loan; for a mortgage insurance purpose; and for any other purpose under the insurance policy issued to us relating to your loan, as well as for other internal management and risk purposes.

If you don't provide personal information to us, it will not be possible for the LMI to process our request for lender's mortgage insurance.

The LMI that we may disclose your personal information and credit information to is:

#### Genworth Financial Mortgage Insurance Pty Ltd.

You can contact Genworth by calling 1300 655 422 or by visiting genworth.com.au.

The privacy policy of the LMI contains information about how you may access the personal information the LMI holds about you, seek correction of that information, and how you may complain about a breach of your privacy. The LMI's privacy policy is available on their website or you can call them to obtain a copy.

The LMI may disclose your personal information to entities located overseas including in the USA, Canada and the United Kingdom.

### Credit Information

Where we collect your personal information and we're likely to disclose that information to a credit reporting body, we're required by law to notify you of certain matters, which are set out below. If you want us to provide you with a hard copy of this information, then please contact us.

#### Which credit reporting bodies does ING DIRECT deal with?

We primarily deal with, and report certain credit-related personal information to, Veda Advantage Business Information Services Ltd (Veda), which is the major credit reporting body in Australia.

You can contact Veda by:

emailing membership.correction@veda.com.au; or

mailing Veda - Customer Resolutions, PO Box 964, North Sydney NSW 2059

#### Collection, use and disclosure of your credit-related personal information

Veda may include your credit information that we provide to it in credit reports to other credit providers to assist those credit providers to assess your credit worthiness.

If you fail to meet your payment obligations in relation to any loan you have with us or if we believe that you have committed a serious credit infringement, we may be entitled to disclose this to Veda.

You can find out further detail about how we manage your credit-related personal information in our Privacy Policy.

In particular, our Privacy Policy sets out how you can:

access the information we hold about you and ask us to correct information if you believe that it is incorrect; and

make a complaint about our handling of your credit-related personal information

Veda's policy on how it handles credit-related personal information can be found on its website at www.veda.com.au/privacy.

#### Pre-screening Assessments

Under the Privacy Act, credit reporting bodies are prohibited from using or disclosing credit reporting information that they hold about you for the purposes of direct marketing. Subject to a number of restrictions, this general prohibition does not apply to the use of this information by the credit reporting body for the purpose of assessing whether you are eligible to receive direct marketing by credit providers, such as ING DIRECT.

This use of the information in this way is known as a "pre-screening assessment".The Privacy Act allows you to request a credit reporting body that holds credit information about you to not use that information for the purposes of a pre-screening assessment. The credit reporting body cannot charge you for making, or carrying out, the request.

#### Fraud - "ban period"

The Privacy Act gives you certain mechanisms to deal with fraud, including identity fraud.

If you believe on reasonable grounds that you have been, or are likely to be, the victim of fraud then you can ask Veda (or any other credit reporting body that holds information about you) not to use or disclose your credit reporting information during a "ban period". 

The "ban period" is a period of 21 days starting on the day that you make the request, which can be extended on your request if the credit reporting body believes on reasonable grounds that you have been, or are likely to be, the victim of fraud.

The credit reporting body cannot charge you for making, or carrying out, the request.

### Access to your personal information

You may request access to limited amounts of personal information that we hold about you - such as your address - by calling us on 133 464. For a more detailed request for access to information that we hold about you, you will need to write to the ING DIRECT Privacy Officer at GPO Box 4094, Sydney NSW 2001.

Please note that requests for access to your personal information may only be made by you or by another person who you have authorised to make a request on your behalf, such as a legal guardian or an authorised agent. We will require you to verify your identity, or the identity and authority of your representative, to our reasonable satisfaction. Depending on the nature and/or volume of the information that you request, an access charge may apply, but not to your request for access itself.

### Updating your personal information

Although we take reasonable steps to ensure that your personal information is accurate, up-to-date, complete, relevant and not misleading, we rely on the accuracy of information that you supply to us. If any of your personal information is incorrect, has changed or requires updating, please assist by either:

updating your details in the 'My Personal Details' section found in your menu selection after you log in; or

contacting us by phone with your client number ready.

### Complaints

ING DIRECT is committed to resolving your privacy complaint as quickly as possible and has procedures in place to help resolve any problems or complaints efficiently. For more information on how to make a complaint, see our complete Privacy Policy under "Making a privacy complaint".

### Data security

We take steps to protect your personal information from misuse, loss and interference. We also protect it from unauthorised access, modification, disclosure.

If we no longer require your personal information for a purpose, for example, to manage your financial product or provide you with a financial service, then we will take reasonable steps to securely destroy it or permanently remove all identifying features from that information.

### Use of internet cookies

ING DIRECT may use cookies to assist you in accessing information on our websites which is of interest and relevance to you. Cookies are a way of storing information on your computer so you do not have to enter the same data every time you access our sites - for instance, your e-mail address. We may also use cookies to capture general information about how you have found our website, or to track the number of visitors to a site, but we do not store any of your personal details when we do this.

### ING Global Privacy Standards

ING DIRECT's parent company, ING Bank N.V., has established global privacy standards for all ING Group companies known as Binding Corporate Rules (BCRs). The BCRs, which are known as the ING Global Data Protection Policy (GDPP), were approved by the Data Protection Authorities in all EU Member States. They are our commitment to protect your personal information and honour our privacy obligations regardless of where your personal information is collected, processed or stored within the ING Group of companies.

### How to contact us

If you have any further questions about privacy at ING DIRECT please contact us by:

calling 133 464

emailing customer.service@ingdirect.com.au

writing to:  
ING DIRECT Privacy Officer  
GPO Box 4094  
Sydney NSW 2001