Use and Disclosure of Personal Information
How Merion uses and shares personal information — and the purposes and limits on that use under Australian Privacy Principles 6 and 7.
APP 6 — Use and disclosure for the primary purpose
Under APP 6, Merion may only use or disclose personal information for the primary purpose for which it was collected, unless an exception applies.
The primary purpose of collecting debtor personal information is to pursue recovery of the debt on behalf of the relevant creditor client. The primary purpose of collecting creditor contact information is to manage the client relationship and facilitate the return of recovered funds. Merion does not use personal information for secondary purposes — such as marketing to debtors or selling information to third parties — without consent or a specific APP 6 exception.
Permitted secondary disclosures
The following secondary disclosures may occur in connection with Merion's services:
- Legal practitioners: where a debt is escalated to legal action, Merion may disclose relevant account information to solicitors engaged to pursue the matter through court, with the creditor's authority.
- Regulatory compliance: Merion will disclose personal information where required by law — for example, in response to a court order, an ASIC investigation, an OAIC inquiry, or an ACCC direction.
- Technology sub-processors: Merion's technology partners process personal information on Merion's behalf under data processing agreements. See Sub-Processors for the current list.
Credit reporting bodies
Merion does not disclose personal information to credit reporting bodies as a standard part of its service. Any engagement involving credit reporting is disclosed to the relevant parties at the time of that engagement, and conducted in accordance with the credit reporting provisions of the Privacy Act 1988 (Cth).
APP 7 — Direct marketing
Merion does not use the personal information of debtors for direct marketing purposes. Debtors will only receive communications from Merion that relate directly to their account.
Merion may contact creditor clients and registered partners about services that are directly relevant to the existing engagement — for example, updates to the debtor portal or changes to fee structures. These individuals may opt out of such communications at any time by emailing [email protected].
Cross-border disclosures
Some of Merion's technology sub-processors are located outside Australia. Where personal information is disclosed to an overseas recipient, Merion takes reasonable steps — including contractual commitments — to ensure the overseas recipient handles the information consistently with the Australian Privacy Principles, as required by APP 8.
Details of sub-processors and their locations are published at trust.merion.com.au/sub-processors/.
What Merion does not do
- Merion does not sell personal information to any third party.
- Merion does not use debtor personal information for any purpose unrelated to the recovery of the specific debt account.
- Merion does not aggregate or on-sell anonymised debtor data for commercial purposes.
Further information
For information about how personal information is collected in the first place, see Collection of Personal Information. For security measures applied to stored personal information, see Security of Personal Information.
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