Credit Reporting Code of Conduct

The draft CR Code application was submitted to the OAIC on 1 July 2013. 


As part of reforms to Australia’s privacy regime, culminating in the tabling of The Privacy Amendment (Enhancing Privacy Protection) Bill 2012, the Privacy Commissioner has mandated a revised Credit Reporting Code of Conduct.


The revised CR Code paves the way for the implementation of comprehensive reporting and improvements to existing reporting practices.


The updated CR Code will assist consumers by ensuring greater transparency and consistency of the risk assessment process and the exchange of more accurate information between Credit Providers and Credit Reporting Bodies. Furthermore, the Code will support improvements in the complaints process, and industry participants will benefit from a Code that provides clear and effective advice on key operational matters.


ARCA established the Code Industry Council (CIC) to facilitate industry consultation, support government engagement and lead the Code’s edification. The Code Industry Council (CIC) appointed an independent reviewer, Chris Connelly, to conduct the first round of stakeholder consultation.


Public consultation was also conducted during April 2013. Submissions made during the public consultation period (and not marked as "confidential") are available here.


The revisions to the CR Code mark the first time the CR Code has been reviewed and the changes are paramount in overseeing a stronger and more transparent credit reporting process.


ARCA strongly advocates data quality and its transparency as the CR Code’s central premise.


Additionally, ARCA proposes that quality data be applied within an Industry Code, via a three-pillar approach consisting of:


1. Single data standard   Ensuring a consistent data standard underpins integrity of the credit reporting system. A single data standard will allow for data to be transparently and efficiently viewed and exchanged. The data standard will support each of the three tiers of data (negative, partial, and comprehensive) and better ensure that data in the credit reporting system is accurate, up-to-date, complete, and correct.
2. Reciprocity   The principle of reciprocity asserts that Credit Providers must contribute all of their chosen level of data (negative, full or partial comprehensive) in order to receive the same level back in return. Reciprocity encourages an information exchange that ensures the most holistic picture of a consumer’s credit profile, promoting more responsible credit practices. ARCA believes that reciprocated information exchanges between providers and bodies is a far more effective means to maintain accurate, up to date, complete and relevant data, than exchanges contracted individually or on a case-by-case basis.
3. Compliance   ARCA supports independent oversight of the Credit Reporting Code of Conduct, through a single regulator. ARCA recognises the need to build a framework that supports a scalable approach to Code compliance, and to promote an environment where compliance standards to the Code are achievable, realistic and address the critical needs of industry and consumers.


ARCA will be supporting a Code development process that meets current best practice standards: