58.2 The ‘Data Quality’ principle in the model UPPs provides that:
An agency or organisation must take reasonable steps to make certain that the personal information it collects, uses or discloses is, with reference to the purpose of that collection, use or disclosure, accurate, complete, up-to-date and relevant.
58.3 Section 18G(a) of the Privacy Act provides that credit providers and credit reporting agencies have an obligation to take reasonable steps to ensure that personal information in a credit information file or credit report is ‘accurate, up-to-date, complete and not misleading’. In addition, the Credit Reporting Code of Conduct provides for the steps to be taken by a credit reporting agency when it becomes aware that information supplied by a credit provider may be inaccurate. If the agency believes that other credit information files may contain similar inaccurate listings it must, as soon as practicable, notify the credit provider and request the credit provider to investigate the accuracy of other files that may be similarly affected.
58.4 The quality of credit reporting information is of fundamental importance to individuals, given the significant consequences that may flow, in terms of future access to credit, from an adverse credit report. Data quality, in the context of credit reporting, has a number of important aspects.
Credit reporting information may be inaccurate because the individual has been identified incorrectly (that is, cases of mistaken identity); or information may be ‘about’ the correct individual, but inaccurate for other reasons.
Credit reporting information may be accurate in objective terms, but not comply with regulatory standards relating to data quality, such as those prescribing the permitted content of credit information files.
The consistency of data reported by credit providers is an important aspect of data quality, because if the same information is reported inconsistently, it may be misinterpreted more easily.
Overdue payment information may be considered inaccurate because: the debt to which the payment relates is disputed; information relating to the same debt has been reported multiple times; or the debt has been paid but repayment has not been recorded.