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Policy Library

Policy Library

To view the policies relating to privacy and usage of this website and applications, please navigate to the document of interest from the list below:

Privacy Policy

Privacy Policy

This policy covers Smartgroup Corporation Ltd and its related bodies corporate ("Smartgroup", "we" or "us"), including Smartgroup Benefits Pty Ltd, Smartfleet Management Pty Ltd, Smartsalary Pty Limited (including Smartleasing and Autogenie, which are registered trade marks of Smartsalary Pty Ltd), Smartequity Pty Ltd, PBI Benefit Solutions Pty Ltd, Smartsalary Software Solutions Pty Ltd, Health-e Workforce Solutions Pty Ltd, Salary Packaging Solutions Pty Ltd, Advantage AccessPay Pty Ltd, AccessPay Payroll Pty Ltd, AccessPay Pty Ltd, Smartsalary Payroll Solutions Pty Ltd, Salary Packaging Solutions Pty Ltd, Autopia Management Pty Ltd, Selectus Pty Ltd and ABM Corporation Pty Ltd (as updated from time to time).

We understand how important it is to protect your personal information. This policy sets out how Smartgroup collects, uses, discloses and holds personal information.

1. Collection of personal information

When we refer to personal information, we mean information about reasonably identifiable individuals. This may include information or an opinion about individuals, whether true or not.

The kinds of personal information we may collect about you include:

  • name;
  • date of birth and age;
  • address;
  • contact details including telephone number, fax number and email address;
  • bank account details;
  • occupation, employment history and employment details, including financial information (including your salary, payroll and employer details) and employee number;
  • photographs;
  • any other information we made need to identify you or to administer our services, including your driver's licence number, car registration or tax file number; and
  • if you are applying for a position with us, credit history, visa or citizenship status and criminal record (see below in relation to sensitive information); and
  • information about how you use and interact with our website.

We may also collect additional information about you depending on the products and services provided:

  • if you apply for finance or a lease - age and number of your dependants, how long you have lived at your current address, your employment details, proof of earnings and expenses, details of income, assets, liabilities, expenses, credit history and credit worthiness;
  • if you apply for insurance, we may collect some information regarding your health (see below), your driver accident and insurance claim history or your driver motor vehicle licence history (restrictions and cancellations).

We may collect your sensitive information only to the extent it is necessary to administer our products or services to you, to assess your application for employment or for employment purposes, and only with your consent. Sensitive information includes membership of professional or trade associations or unions, membership of a political association, or health information or and, in an employment context, your criminal history, racial or ethnic origin, religious beliefs and sexual orientation.

Where reasonable and practical we will collect your personal information directly from you, such as via application or enquiry forms or other documents that you submit to us; when you contact us via phone, email or our websites or social media accounts; when you attend one of our events; or when you submit a CV or application for employment to us. If you do not provide the information requested by us, we may not be able to provide you with our products or services or respond to your enquiry.

Depending on the product or service provided or your relationship with us, we may also collect your personal information from third parties, for example, from your employer, your employer's outgoing salary packaging service provider or your financial planner. If you are applying to work for us, we may collect personal information through recruitment companies, websites, other organisations and referees with your consent. We may also collect your personal information from our related bodies corporate, where we are permitted under law to do so or have otherwise obtained your consent.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy. The individual must also provide the consents set out in this Privacy Policy in respect of how we will deal with their personal information.

2. Use of personal information

We use your personal information for the purpose for which it has been provided, reasonably related secondary purposes which are within the contemplation of the parties (and are directly related if the information is sensitive information), any other purpose you have consented to and any other purpose permitted under the Privacy Act 1988 (Cth). This may include using your personal information for the following purposes:

  • to verify your identity;
  • to enable us to establish and administer our products and services;
  • for the purpose of managing our relationship with you, including dealing with your enquiries;
  • to provide you with, monitor, and develop our website services, including via the use of cookies;
  • to deal with any enquiries or communications with you or any agency or representative, including any application for employment;
  • to comply with our legal and regulatory obligations including any recommendation, request, rule, order or direction of any regulatory, governmental authority, securities exchange, court or tribunal;
  • to conduct marketing activities across the group, for example, on occasion we may offer you other products and services, including from our related bodies corporate;
  • to conduct market research and statistical analysis in relation to our business;
  • if you are applying to work for Smartgroup, to carry out the recruitment process, or assess your suitability for future roles; and
  • where we are required or authorised to do so by law,

and for any other purpose related to or ancillary to any of the above.

3. Disclosure of personal information

We disclose your personal information for the purpose for which it has been provided, reasonably related secondary purposes which are within the contemplation of the parties (and are directly related if the information is sensitive information), any other purpose you have consented to and any other purpose permitted under the Privacy Act. Depending on the product or service we are providing to you, or your relationship with us, we may disclose your personal information:

  • to your employer;
  • to a bank or financial institution;
  • to our third party suppliers and vendors to the extent necessary for the establishment, provision, and administration of the applicable products or services (this may include car dealers, intermediaries, financiers, valuers, insurers, credit reporting agencies or lawyers/debt collectors). For example:
    • if you are an Autogenie client, we will disclose your personal information to your chosen car dealership;
    • if you are applying for or have a novated lease, we will disclose your personal information to, and otherwise deal with, the applicable financier and car dealership in setting up and administering your lease;
    • if you are applying for or have an insurance policy, we will disclose your personal information to the applicable insurer; or
    • if you have a salary packaging arrangement with us, we may disclose your personal information to applicable suppliers, for example, mechanics, fuel companies, statutory authorities in relation to vehicle registration/insurance, and superannuation funds for the purpose of processing your superannuation contributions;
  • to our personnel, agents, contractors and service providers that are involved in providing, managing or administering the applicable products or services (eg printing and postal services, call centres and mail houses);
  • to those companies who provide information and infrastructure systems to us, including cloud storage providers;
  • to anyone acting on your behalf;
  • to our professional advisors and consultants, accountants, lawyers and auditors;
  • to anyone else in relation to whom you have provided us consent;
  • to any company within Smartgroup;
  • if you are applying to work for Smartgroup, your referees, the Australian Federal Police (to undertake criminal history checks), educational and professional obligations (to verify academic qualifications, licences and memberships), to organisations that conduct competence and psychometric tests, and the Department of Immigration and Citizenship (to verify your right to work in Australia); and
  • where we are required to do so by law,

and for any other purpose related to or ancillary to any of the above.

One of the ways we store and manage information (including personal information) is by using cloud computing, where servers are based overseas including in Japan and the USA. We take reasonable steps to maintain the security of your information and to ensure your information is treated in accordance with the standards that apply in Australia.

4. Direct marketing

We may from time to time use your personal information to provide you with current information about loans, insurance products, special offers you may find of interest, changes to our organisation, or new products or services being offered by us, our related bodies corporate or any other company we are associated with. By providing us with your information, you consent to receiving such information, including by phone, email, SMS and social media, on an ongoing basis until you unsubscribe. We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.

If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us. Contact details are set out at section 11 of this policy. If the direct marketing is by email you may also use the unsubscribe function and if the direct marketing is by SMS you may reply 'STOP' to opt out. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

5. Cookies, advertising and tracking

Please refer to our Terms of Use available at ( (insert a valid link to the terms of use on Smartfleet website) for information on how we use cookies on our websites and online advertising.

Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.

6. Accessing, updating and correcting your personal information

You can request to access your personal information we hold at any time. Depending on the volume or difficulty in obtaining the information, we may charge a fee that covers our costs.

An initial response will be provided to you within 7 days from your request, and the outcome of the investigation given in 30 days. There may be situations where we are not required to provide you with access to your personal information, and we will set out the reasons for this. An example of this would be where the information related to existing or anticipated legal proceedings, or if your request was vexatious.

You may also request to correct any of your personal information we hold if it is incorrect, inaccurate or out of date. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.

Depending on the request we may update your personal information immediately, or we may provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days from your initial request. We may have to consult with external entities as part of your request to access or correct your personal information.

7. Using government related identifiers

If we collect government related identifiers, such as your drivers licence number or tax file number, we do not use or disclose this information other than to the extent required or authorised by law. For instance, we will never adopt your tax file number as your account number to identify you.

8. Doing business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without you providing us with personal information, for example where you make general enquiries about our products or services, or any special offers.

9. How safe and secure is your personal information that we hold?

We may store your personal information in paper or electronic form. We will take reasonable steps to protect any personal information from misuse, interference, loss and unauthorised access, modification or disclosure. We do this by:

  • installing security and access requirements for all our IT systems, such as passwords, firewalls and virus scanning software;
  • having document storage and destruction policies;
  • only providing you your personal information where we are satisfied as to your identity; and
  • encrypting data and other personal information during internet transactions (if any).

When the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.

10. Complaints

If you are dissatisfied with how we have dealt with your personal information, or have a complaint about our compliance with the Privacy Act, you may contact us using the details in clause 10. We will acknowledge your complaint within seven days and provide you with a decision on your complaint within 30 days. If you feel your complaint is still not resolved adequately after discussion with us, you may then take the complaint to the Credit & Investments Ombudsman (CIO) if it relates to our role as a financial services provider, or contact the Office of the Australian Information Commissioner on

11. Further information

If you have any questions about how we handle your personal information, contact our Privacy Officer by phone on 1300 476 278, via email at, or at:

Privacy Officer
Smartgroup Corporation Ltd
GPO Box 4244, Sydney NSW 2001

12. Changes to our privacy policy

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. As a consequence we may change this privacy policy from time to time or as the need arises.

Last updated: 9 November 2017

Website Terms of Use

About these Terms of Use

These Terms of Use apply to the use of this website (the 'Website'), including the use of the information offered on this Website, which is operated on behalf of Smartgroup Corporation Ltd (ACN 126 266 831) and its related bodies corporate ('we', 'us' and 'our').

These Terms of Use incorporate our Privacy Policy, which is accessible at (URL).

In using this Website, you agree to be bound by these Terms of Use (including our Privacy Policy). If you do not accept these Terms of Use, you must refrain from using the Website.

We may change these Terms of Use from time to time, and such modifications will become effective upon posting the modified Terms of Use on the Website. Any use of the Website by you after such modified Terms of Use have been posted will be deemed acceptance by you of those modified Terms of Use.

Information on the Website

You must not access or use this Website for any purpose that is unlawful or prohibited by these Terms of Use.

You must take your own precautions to ensure that the process which you employ for accessing this Website does not expose you to the risk of viruses, malicious computer code or other forms of interference which may damage your own computer system. Except as required by law, we do not accept responsibility for any interference or damage to your own computer system which arises in connection with your use of this Website or any Third Party websites.

The information provided on this Website is of a general nature only, and does not constitute financial advice. You should make your own enquiries before acting or relying on any information or material which is made available to you pursuant to the Website.

Information from third parties

The Website also contains links to the websites of third party providers of goods and services ('Third Party websites'). Those links are provided for convenience only and may not remain current or be maintained. We are not responsible for the content or privacy practices associated with Third Party websites.

Our links with Third Party websites should not be construed as an endorsement, approval, affiliation with or recommendation by us of the owners or operators of those websites, or of any information, products or services referred to or contained on those websites, unless and to the extent stipulated to the contrary.

If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.

Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.

Advertising and tracking

When you view our advertisements on a Third Party website, the advertising company uses 'cookies' and in some cases 'web beacons' to collect information such as:

  • the server your computer is logged on to;
  • your browser type;
  • the date and time of your visit; and
  • the performance of their marketing efforts.

When you access our Website after viewing one of our advertisements on a Third Party website, the advertising company collects information on how you utilise our Website (e.g. which pages you view and whether you proceed to obtain services from us).


We use 'cookies' to provide you with better and more customised service and with a more effective website. A 'cookie' is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser. We use cookies for different purposes such as:

  • to allocate a unique number to your internet browsers;
  • to customise our website for you;
  • for statistical purposes;
  • to identify if you have accessed a Third Party Website; and
  • for security purposes.

You are not obliged to accept a cookie and you can modify your browser so that it will not accept cookies. However, if you do so this may affect your browsing experience and certain functions within the Website may not work.

IP addresses

Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our Website.

Online applications

When you send a completed online form or provide information through our Website to us, we retain the information you have sent us. We are able to then use that information to provide any services that you require.

You can also suspend and save the online form, so you can complete and send the form at a later time. If you suspend or save your form, the information that you have entered will be retained in our systems so that you may recover the information when you resume your form. Online forms that have been suspended or saved may be viewed by us.

Security of information

The security of your information is very important to us. We regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as totally secure.

We take reasonable steps to preserve the security of cookie and personal information in accordance with our Privacy Policy, however we do not warrant and cannot ensure the security of any information which you transmit to us. Accordingly, any information which you transmit to us is transmitted at your own risk. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).

Intellectual property

Copyright in this Website (including text, graphics, photographs and logos) is owned or licensed by us. Information procured from a third party may be the subject of copyright owned by that third party. Other than for the purposes of, and subject to the conditions prescribed under, the Copyright Act 1968 (Cth) and similar legislation which applies in your location, and except as expressly authorised by these Terms of Use, you may not in any form or by any means:

  • adapt, reproduce, store, distribute, print, display, perform, publish or create derivative works from any part of this Website or from any information obtained from this Website, including in association with any Third Party Websites; or
  • commercialise any information, products or services obtained from any part of this Website;
  • without our written permission or, in the case of third party material, from the owner of the copyright in that material. You must not use any content from the Website in a manner that suggests that you are approved by or affiliated with us.

This Website includes trade marks owned by us (or our licensors). You must not use any of our trade marks in or as the whole or part of your own trade marks or business name or company name; in connection with activities, products or services which are not ours; in a manner which may be confusing, misleading or deceptive; or in a manner that disparages us or our information or services (including this Website).

Governing Law

These Terms of Use are governed by the laws in force in New South Wales, Australia. You agree to submit to the exclusive jurisdiction of the courts of that jurisdiction.

Last updated: 20 November 2017

Customer Service Charter

As a customer of a Smartgroup company, you can expect a simple and rewarding experience that is easy to understand and even easier to manage.

We continually look for ways to innovate and simplify the products and services we offer, and ask you, our customer, to let us know how we're going so that we may learn from your experience dealing with us - both good and otherwise. Our unwavering commitment is widely recognised by our peers, having received more awards for customer service and innovation than any other company in our industry, and we're proud to be accredited by the Customer Service Institute of Australia (CSIA).

Our commitment to you

Our mission is to make the services we offer easy to understand, and for them to be simple and seamless so that you may take full advantage of your benefits.

We will:

  • Be friendly and helpful
  • Explain clearly your benefits and how they work
  • Direct you to the best person to answer or resolve your enquiry first time
  • Respond to email and social media queries within two business days
  • Provide a transparent and competitive fee structure
  • Keep you up-to-date with any changes that impact your benefit arrangements
  • Invite you to provide open and honest feedback so that we may improve our service delivery
  • Continue to seek new ways through innovation and technology to improve our services and make them easy to understand and even easier to access.

We value your feedback - it's what drives us to improve the way we serve - so if you feel we're not meeting this commitment to you, we'd like to know about it. To lodge a complaint and understand how your complaint will be handled, see our Complaints Charter.

So that we can provide the service you've come to expect from us, we ask that you:

  • Read the updates we send regarding your account;
  • Let us know immediately when there are changes to your personal details, including your employment status;
  • If you're taking personal leave that affects your pay dates, like long service or parental leave; and
  • Be courteous to our service staff.

Get in touch with us whenever and however it suits

We're here to assist when you need us. To find the communication channel that suits you, see Contact Us.

We respect and protect your personal information

Our Privacy Policy explains how we ensure the security and privacy of your personal and financial information.

For your peace of mind, we:

  • Have an onsite risk management team dedicated to the protection of our customers' private and sensitive information;
  • Will never sell personal information to other organisations for marketing purposes;
  • Facilitate your right to access your personal information, as stated in our Terms of Use.

Complaints Charter

We welcome your feedback

The feedback we receive from our customers is as at the heart of the improvements we make to our service delivery. So we welcome your feedback, good and otherwise.

If you would like to let us know about an experience you've had, email us at or call 1800 555 582 to speak with a member of our service team.

How to make a complaint

When things don't go as they should, and you feel we're not meeting our commitment to you, we appreciate you letting us know.

To ensure a satisfactory resolution, contact the team handling your benefits on 1800 555 582, or email

How we handle your complaint

  • Within 48 hours, you'll receive a response from us, with either a resolution or an update on the matter
  • Our aim is to have the issue resolved to your satisfaction within two weeks
  • If you are dissatisfied with the resolution offered or the investigation into your complaint, we will escalate it to the next level of management who will work directly with you to resolve the issue.

What to do it you are not satisfied with the outcome

  • We ask that you continue communicating with us so that we may have the opportunity to resolve the issue to your satisfaction
  • As a last resort, you may choose to contact the Financial Ombudsman Service (FOS). Should you choose to contact the Ombudsman, ensure you have your Advantage Salary Packaging case number.

    Financial Ombudsman Service (FOS)
    Phone: 1800 367 287