OAIC view on temporary arrangements better positions industry to plan for CCR data sharing
In January, we reflected on the uncertainty being brought on by the FOS draft determination in relation to RHI status regarding temporary payment arrangements. Pleasingly, progress has been made with the Office of the Australian Information Commissioner (OAIC) expressing their view on an interpretation of the Privacy Act that supports the Industry view – retaining the efficacy of repayment history information.
During the process, both ARCA (Australian Retail Credit Association) and the OAIC have recognised that a key issue relates to the communication (written and verbal) between the lender and the consumer being critical to interpretation. We would expect that lenders may need to review call centre scripting to ensure the consumer is aware of the status and requirements of their existing credit contract, when a temporary payment arrangement is permitted by the lender. Similarly, we would anticipate that credit providers will be best placed to be relatively aligned to ensure the communication with consumers is consistent when dealing with situations relating to temporary payment arrangements.
Early movers to Comprehensive Credit Reporting (CCR) are aware of the OAIC letter and its content, and a number have discussed the near term resumption of their CCR data sharing plans. This is positive for regaining momentum on the CCR transition journey and timely given that the Productivity Commission will shortly release its findings on the enquiry into Data Availability and Use. This report will detail the Productivity Commission’s recommendation to government on expectations for the timelines to CCR critical mass.
Angus Luffman, General Manager Consumer Products, Equifax