Frollo, as an Accredited Data recipient, provides financial services that can access your personal banking information securely via the governments’ Open Banking initiative. The rules for Open Banking are defined by the Consumer Data Right (CDR) which aims to provide greater choice and control for Australians over how their data is used and disclosed.
Collection of your personal banking data
Frollo adopts a data minimisation approach and only collects banking information which is necessary to provide its financial services.
There are no fees for accessing your personal banking data and Frollo does not accept consumer requests to access any additional data such as voluntary product or consumer data that the bank may have but not obligated to supply under the CDR rules.
All data collected, with a person’s consent, is used in providing Frollo personal finance services. In this context, data which Frollo will access for the duration of the consent is:
- customer and account information,
- bank balances,
transactions made to and from the bank account nominated.
- and contact details
Frollo will collect and use your data in accordance with the purpose of the service we are providing. Frollo provides a consent dashboard for the management of your consents which includes a receipt of the consent, its scope and duration with a summary of the data received. You can revoke your consent at any time from the consent dashboard.
Classes of CDR data
The following classes of data are held by Frollo and used to provide financial services through its mobile app and Web applications:
- Name of account
- Type of account
- Account balance
- Account number
- Interest rates
- Account terms
- Account mail address
- Incoming & outgoing transactions
- Descriptions of transactions
- Who you have sent money to and received money from (e.g. their name, BSB, account number)
Other services we offer might provide you with the option to choose whichever types of data you like, including those shown below. We’ll always tell you if we need a particular type of information to deliver our service to you.
- Email address
- Mail address
- Residential address
- Obtain direct debit authorisations
- Obtain scheduled, outgoing payments
- Names and details of saved payee accounts
Purposes of CDR data
Account information, transaction and contact details are collected and used by Frollo in accordance with the following services.
- Personal Financial Management uses this information to provide users with insights about where their money is going, and tools to manage their money more effectively.
- Financial Passport uses this information to provide insights on your finances, producing a detailed Financial Passport that can be used when applying for loans
To provide a positive consumer experience and ensure consumer control over their data, Frollo does not provide information to third parties to engage in direct marketing. We may send information to customers from time to time relating to products and services that can assist with their financial goals and general financial wellness.
Frollo does not disclose or use your personal data (including banking data) for commercial purposes.
Outsourced service providers
Frollo does not provide CDR data to any outsourced providers. Frollo develops and maintains its own software for use with banking data collected under the CDR Rules.
Accessing and correcting your personal information
A user can request correction of their data through the contact us channels listed below.
Sufficient details must be provided to assess the issue and make corrections. Once assessed, notice is given over email that states what Frollo did in response to the request, any corrective action or comments, and the ability to make a complaint if not satisfied.
How to contact us
How to make a complaint
If you believe that there has been a breach of the CDR rules by Frollo, please submit your CDR consumer data complaint via email to firstname.lastname@example.org.
Please include the following information when submitting your complaint.
- Your name;
- Your contact details;
- Your preferred contact method of complainant (phone / email / letter); and,
- The details of your complaint.
A CDR complaint can be made at any time. Once your complaint is received, Frollo will immediately acknowledge receipt of the complaint within five (5) business days of being received.
Frollo will investigate your complaint and attempt to provide you with a written response to resolve the complaint, within thirty (30) calendar days of receipt of your complaint.
If your complaint remains unresolved after thirty (30) calendar days, you will be advised in writing that additional time is required to complete the investigation and to provide a response.
When the complaint is resolved, you will receive a ‘final response’ letter within 45 days, informing you of:
- the final outcome of your complaint or dispute;
- your right to take their complaint or dispute to External Dispute Resolution; and
- if you are not satisfied with the response, you may lodge a complaint with the Australian Financial Complaints Authority.
If your complaint remains outstanding within forty-five (45) days, Frollo must write to you to:
- inform you of the reasons for the delay;
- specify a date when a decision can be reasonably expected;
- informs your of your right to take your complaint or dispute to an External Dispute Resolution; and
- if you are not satisfied with our response, you may lodge a complaint with the Australian Financial Complaints Authority.
Events for notifying CDR consumer
Frollo does not make a consumer’s banking data accessible or visible to outside
organisations. Frollo employs stringent up to date information security practices.
In the event of a data breach e.g. someone gaining unauthorised access which results in loss of CDR data, we would notify a CDR consumer as soon as practical in order for the consumer to take appropriate action if required.
Consequence of withdrawing consent
When you stop sharing data with Frollo, then we will stop collecting data from this account. We will also delete any data we previously received from this account.
Without this data, we will be limited in our ability to help you track your budget.
The detailed impact to using Frollo is as follows:
- Transaction Details: If you stop sharing these details we will no longer be able to identify how much money you have spent.
- Direct debits and scheduled payments: If you stop sharing these details we will no longer be able to identify the amount of regular payments you make.
- Customer Details: If you stop sharing these details we will no longer be able to identify your name
Deleting CDR data
You can stop sharing data with us at any time by going to your consent dashboard or by writing to us at email@example.com
We will delete all banking data collected under a user’s consent, along with any derived data, within 24 hours of the following events:
- Your consent for access to banking data expires
- You stop sharing data with us before consent expires, or, you request data sharing to stop via the bank holding the account
- You delete your Frollo account
- Your bank notifies us that you cease to be an eligible consumer with them
When any of these events occur Frollo will delete all the data you shared with us from our systems, unless it is required to be held by Australian law.
Availability of policy
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