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Safeguarding customer privacy when raising and recovering debts 107-05010050



This document outlines details of the appropriate use of customer information for recovery of debts.

On this page:

Protecting the customer's privacy when contacting by phone

Protecting the customer's privacy when issuing a debt notice

Protecting the customer's privacy when contacting by phone

Table 1

Item

Description

1

Speaking to a customer on the phone + Read more ...

Authenticate the Centrelink customer over the phone before discussing details of the debt:

  • if the call is initiated by Debt Staff:
    • identify who they are, and
    • the reason for the call
  • check the contact details recorded for the customer are correct and update if necessary
  • do not record phone number information from a phone's call number display without first asking the customer if it is a correct contact point for them
  • see Call and screen recording - information and access for the correct script to use for inbound/outbound calls and when a third party enters the conversation

2

When a third party answers the phone + Read more ...

Ask to speak to the customer:

  • staff should only give their name and identification (for example, Services Australia) to a third party if they request it
  • do not tell a third party the reason for the call
  • do not talk about debt recovery to the third party
  • for third parties with express and implied authority, including Partner Permitted to Enquire (PPE), see Item 5

3

Leaving messages when attempting to contact a customer + Read more ...

Leave a message if the matter is urgent.

Where the customer's name is not included in the greeting, Debt Staff should leave the following details:

  • their name
  • identification (for example, Services Australia), but not mention their team (for example, Debt Program)
  • a contact phone number, and
  • a deadline time for contact, for example, 'by 5:00pm tomorrow'

Do not leave information about the reason for the call.

4

Leaving messages when attempting to contact a third party (for example, employer) + Read more ...

Do not give:

  • the employee's name
  • Customer Reference Number (CRN)
  • information about the reason for the call

Only leave a message with a third party if the matter is urgent.

If a message is left with a third party, Debt Staff should leave:

  • their name
  • identification (for example, Services Australia), but not mention their team (for example, Debt Program)
  • a contact phone number, and
  • a deadline time for contact, for example, 'by 5:00pm dd/mm/yy'

5

When speaking to third parties (express and implied authority) + Read more ...

When providing information to third parties, ensure the customer has given express authority before:

  • discussing the reasons for the debt, or
  • releasing any information about the debt to a third party

Verify the identity of the person with express authority before providing information about the debt.

Third parties with express authority include:

PPE, PPU and NOP:

  • do not have the authority to enter into repayment arrangements on the customer’s behalf
  • Service Officers must not freely discuss or alert to the customer’s debt, unless that was the reason for the PPE contacting or enquiring
  • PPE must ask for information about the customer's debt before it is provided

NOC:

  • do have the authority to enter into repayment arrangements on the customer’s behalf
  • Service Officers must not freely discuss or alert to the customer’s debt, unless that was the reason for the NOC contacting or enquiring
  • NOC must ask for information about the customer's debt before it is provided

Third parties contacting with implied authority do not have authority to enter into repayment arrangements on the customer’s behalf.

All details of the discussion must be recorded on a DOC, including the name, address and phone number of the third party.

6

When asking a third party for information + Read more ...

Give sufficient information to positively identify the customer:

  • do not give details of the debt to the third party
  • ask for information necessary for recovery purposes

Protecting the customer's privacy when issuing a debt notice

Table 2

Step

Action

1

Debt advice delivery method + Read more ...

If the customer is registered to receive agency communication via online channels (myGov), debt notification letters will be issued via this platform where possible. To check a customer's registration status:

  • open Customer First > Workspace > Self Service > Electronic Messaging and online letter services
  • the Electronic Messaging and Online Letter Services (EMOL) screen displays current subscription details

Check if the customer:

  • is in receipt of a payment
  • has a current address on record that has been updated in the last 12 months on the Address History (ADH) screen
  • is registered to receive agency communication that can be delivered electronically via online channels (myGov)

Does the customer meet one of the above criteria?

2

Online Search (OLS) Facility access + Read more ...

Conduct an Online Search (OLS) to locate the customer’s address.

OLS draws on current and some historical Centrelink customer data and limited data from the Australian Electoral Commission (AEC) and Medicare Australia (HIC) as user access permits. Users can search for information by names, addresses, birth dates or bank account details or any additional search fields. Debt Staff should utilise OLS to confirm or update customer address details.

To undertake an OLS search:

  • APS staff who currently have access to OLS, go to Step 3
  • Contractors and Labour Hire staff who require access to OLS:
    • see Table 1 on the Resources page for the responsibilities of using OLS and steps required to obtain access to OLS
    • once access is approved, go to Step 3
  • Payment Assurance Operations (PAO) Managers who require OLS access for staff, see Table 2 on the Resources page for the responsibilities of and actions required by a Line Manager
  • all other areas, see Online Search (OLS) facility

3

Logging in to OLS and conducting a search + Read more ...

See Online Search (OLS) facility to:

  • log in to OLS
  • conduct the relevant searches, and
  • go to Step 4

4

Online Search (OLS) Facility results + Read more ...

If the most recent address in OLS matches the address currently held on the Centrelink record:

  • the address will be considered verified
  • the debt related notice will be issued to this address
  • go to Step 5

If the last address in OLS is older than the address on the customer’s Centrelink record:

  • the address on the Centrelink record is considered the most up to date
  • the debt related notice will be issued to the most recent address already recorded on the customer's record
  • go to Step 5

If the OLS identifies a new address, not previously known to Centrelink:

  • the agency will consider the new address has been obtained from a reliable source
  • update the customer record with the verified address
  • the debt related notice will be issued to the new address
  • go to Step 5

If the OLS does not match any new or pre-existing address, the agency has taken reasonable steps to verify the current address of the customer. If no information has been identified that suggests the existing address is incorrect:

  • the debt related notice will be issued to the existing address on record
  • go to Step 5

5

Document the record + Read more ...

Document the record with the search channel (OLS) and the result.

Go to the relevant Operational Blueprint procedure to proceed with the appropriate debt raising and/or recovery action.