Submission - Credit Reporting Regulatory Framework: Submission to ALRC Privacy Inquiry (December 2007)

2.1. Definition of potential harm

This Report adopts a broad definition of ‘harm’, including harm to both individual consumers and the wider community.

This Report broadly distinguishes between privacy harms and general consumer harms, even though it is recognised that consumer protection includes privacy protection. The split is useful when describing key issues and regulatory options.

This Report also describes consumer concerns about industry practice, using the terms responsible lending and responsible credit marketing. We believe the term responsible lending has, in practice, been restricted to the actual decision to provide credit. Many consumer concerns arise from an earlier stage – the marketing of credit products – and this Report attempts to address both areas of concern.

This Chapter discusses a broad range of potential consumer and privacy issues that might arise in a credit reporting environment.