Automated Decision Making, including profiling, is the processing of personal data
(that we have collected or are allowed to collect from others) by automated means
and without human involvement to evaluate personal aspects about you.
In particular, we may process data to analyse or predict (amongst other things)
your financial situation, personal preferences, interests or behaviours.
This means that automated decisions without human involvement could be made about
you for example in relation to the products and services we offer you
(e.g. credit limit change decisions or deciding which communications are suitable for you).
Here are the types of automated decisions we make:
Making Lending Decisions
For our credit products, we use automated decision making when deciding whether
to lend money to you and to determine the initial setup for our products
(e.g. what credit limit you will be offered on your credit card).
When you have an account with us, we may continue to use automated decision making
where deciding whether to offer you additional credit (e.g. where offering you a
credit limit increase).
Where making assessments of this type, we may use a technique known as "credit scoring".
Credit scoring uses data from several sources:
- information you have provided;
- information we may collect or already hold about you; and
- information provided by third parties (including credit reference agencies)
We use data from these sources and our logic to predict behaviours
(e.g. how well we expect you to manage your product and make regular
payments), to group our customers (or potential customers) into
'customer segments' and to make our lending decisions (e.g. which
applicants do we accept / decline).
This approach allows us to make quick, consistent decisions, uphold our
lending requirements and ensure that we lend responsibly. These automated
decisions may lead to your credit application being declined and may limit
your ability to access further credit in the future.
Detecting Fraud
Where you apply for (or register for) one of our products or services,
we use automated processes to detect and help prevent fraud.
We may automatically decide that you pose a fraud or money laundering
risk if our processing reveals your behaviour to be consistent with
money laundering or known fraudulent conduct; or is inconsistent with
your previous submissions; or you appear to have deliberately hidden your true identity.
We may also continue to monitor your accounts, your product usage and your
transactions to determine whether your account is being used for fraudulent activities.
We utilise data from several sources to help us identify fraud risks:
- information you have provided;
- information we may collect or already hold about you; and
- information provided by third parties (including fraud prevention agencies)
We combine data from these sources and defined logic to identify threats and
prevent fraud losses. If we think there is a risk of fraud, we may stop
activity on your account and/or refuse access.
Providing you with access to products and services
When you apply (or register) for one of our products or services,
we perform checks to ensure that these are suitable for your
circumstances and that we manage our business risks.
To do so, we utilise data from several sources:
- information you have provided;
- information we may collect or already hold about you; and
- information provided by third parties.
These checks may include (but are not limited to):
-
checks to ensure you meet conditions for opening
an account (e.g. checking your age and residence);
-
checks based on your existing products with us (e.g. checking whether you
already have an account with us and how it is currently being managed);
-
checks to identify money laundering, criminal / terrorist activity or
cyber security threats that may pose a risk to you and our business.
Where we identify circumstances or threats that introduce a risk to you or our business,
we may not be able to provide you with access to our products or services.
Managing, tailoring and marketing our products and services
Where we have an existing relationship with you, we may use profiling and
automated decision making to help manage this relationship. We use these
techniques to ensure that we manage your accounts, products or services appropriately;
help you get the best out of your products and services; and provide you with
promotions or offers that we think you will be interested in.
We use data that you provide along with internal and third-party data to
place you into groups with similar types of people. We call these groupings
'segments' and these are used to help us understand, test and tailor our products,
services and marketing more appropriately depending on identified segment types.
Some examples of how we use profiling and decision making are:
-
Optimising and fulfilling on communications different communication
approaches are suitable for different types of people so we use segmentation to
provide you with the most appropriate communications for you;
-
Sending marketing and offers different marketing approaches may be
used with certain segments where we think our marketing will perform more effectively;
-
Tailoring or managing products we may tailor your accounts,
products or services based on a segment that you are grouped into
(e.g. changing product terms such as APR, closing accounts that have been
inactive or taking action to prevent customer indebtedness).
This approach helps us to manage our accounts, products, services and marketing
more effectively and meet industry and regulatory requirements
(e.g. around customer indebtedness). This profiling and automated decision making may
lead to changes on your account, product or service or in the way that we interact with you
(communications or marketing).
Your rights in relation to automated decision making
You have rights in relation to certain automated decision making which means that
before the end of the period of one month beginning with receipt of the automated
decision you can request us to:
- reconsider the decision; or
- take a new decision that is not based solely on automated decision making and ask that a person review it.
If these rights apply you will be notified. If you want to know more about these rights, please contact us.