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Credit Management Policy

IPSTAR Credit Management Policy

(Prepared under the Telecommunications Consumer Protections Code C628:2012 (TCP Code), the Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2025, and the Telecommunications (Financial Hardship) Industry Standard 2024)

Version: 2025.1
Date: 02/10/2025

1. Purpose and Legal Framework

This Policy sets out how IPSTAR Australia Pty Limited (IPSTAR) manages the supply of telecommunications services in circumstances where credit risk must be assessed or controlled.

It has been prepared in compliance with:

  • Telecommunications Consumer Protections Code C628:2012 (TCP Code) — Chapter 6 (Credit Management);
  • Telecommunications (Financial Hardship) Industry Standard 2024 made under the Telecommunications Act 1997 (Cth);
  • Privacy Act 1988 (Cth) — including Part IIIA (Credit Reporting) and the Australian Privacy Principles (APPs); and
  • Privacy (Credit Reporting) Code 2025 (CR Code) registered under s26S of the Privacy Act 1988.

This Policy is not a substitute for the Codes or legislation themselves, and should be read in conjunction with them.

2. Application of this Policy

This Policy applies to:

  • Residential and small business customers of IPSTAR in Australia; and
  • All circumstances where IPSTAR provides telecommunications services involving a credit risk.

Financial hardship obligations are addressed separately in IPSTAR’s Payment Assistance (Financial Hardship) Policy, issued pursuant to the Financial Hardship Standard 2024.

3. Credit Assessment

3.1 Assessment of Applications

Under Chapter 6 of the TCP Code, IPSTAR may, when assessing an application for service:

  • Conduct a credit assessment in accordance with Part IIIA of the Privacy Act 1988 by obtaining a credit report from a Credit Reporting Body (CRB); or
  • Provide services with credit-limiting features such as pre-paid arrangements, spend caps, or usage restrictions.

3.2 Obligations when refusing service

If IPSTAR refuses to supply services based on credit information, IPSTAR will comply with s21C of the Privacy Act and the CR Code 2025 by providing:

  • The name and contact details of the CRB;
  • The general reasons for refusal;
  • Information on how to obtain a copy of the credit report; and
  • Advice on the customer’s rights to request correction and make a complaint.

4. Credit Reporting

4.1 Disclosure to CRBs

Pursuant to s21D of the Privacy Act 1988 and the CR Code 2025, IPSTAR may disclose credit information to a CRB, including:

  • Identity particulars;
  • Details of applications for credit;
  • The fact that IPSTAR is a current credit provider;
  • Repayment history and overdue debts (≥ $150, ≥ 60 days overdue, after notice);
  • Serious credit infringements; and
  • The fact that credit has been paid or discharged.

4.2 Default Listings

In compliance with clause 9 of the CR Code 2025 and s21C Privacy Act:

  • Defaults may only be listed if the debt is ≥ $150, at least 60 days overdue, and statutory notices (including a 14-day final notice) have been given.
  • Defaults cannot be listed if the debt is subject to a hardship arrangement or is genuinely disputed.

4.3 Corrections

In accordance with s21V of the Privacy Act and clause 20 of the CR Code 2025:

  • IPSTAR will take reasonable steps to correct any credit information found to be inaccurate, incomplete, out-of-date, irrelevant, or misleading.
  • Customers will be notified of correction outcomes within 30 days, or provided with written reasons for any delay.

5. Spend Management and Credit Control Tools

As required by TCP Code Ch 6.5, IPSTAR provides the following tools to assist customers in managing usage and charges:

  • Pre-paid services;
  • Hard caps or spend limits on eligible plans;
  • Usage notifications (by email or SMS);
  • Data shaping (reduced speeds after quotas are reached); and
  • Optional service suspensions (as permitted under the Standard Form of Agreement).

6. Unbilled Amounts

Under TCP Code Ch 6.6, IPSTAR provides customers with access to information on unbilled amounts by contacting 1300 464 778 (Mon–Sat, Australia-wide).

7. Credit Management Action

7.1 Actions available

Where a customer fails to pay by the due date, IPSTAR may, consistent with TCP Code Ch 6.7, take credit management actions including:

  • Issuing reminder and overdue notices;
  • Adjusting billing cycles for credit control;
  • Restricting, suspending, or disconnecting services;
  • Referring debts to collection agents; or
  • Listing defaults with CRBs (subject to section 4 above).

7.2 Notice Periods

  • TCP Code obligation: At least 5 working days’ written notice before restriction, suspension, or disconnection.
  • Financial Hardship Standard 2024 obligation: At least 10 business days’ written notice where the customer is in, or being assessed for, a hardship arrangement.
  • Where both apply, the longer notice period prevails.

7.3 Disputed Amounts

In accordance with TCP Code Ch 6.8 and s21D Privacy Act, IPSTAR will not take credit management action in relation to genuinely disputed amounts while the dispute remains under investigation by IPSTAR, the Telecommunications Industry Ombudsman (TIO), or another recognised body.

7.4 Exceptions (no notice required)

IPSTAR may suspend or restrict without prior notice if:

  • Fraud or attempted fraud is reasonably suspected; or
  • The account presents an unacceptably high credit risk (TCP Code Ch 6.9).

8. Relationship with Payment Assistance (Financial Hardship) Policy

Under the Financial Hardship Standard 2024 and TCP Code Ch 6.10:

  • Customers experiencing payment difficulties must be referred to IPSTAR’s Payment Assistance (Financial Hardship) Policy.
  • While a hardship arrangement is active, IPSTAR will not pursue default listing, suspension, or disconnection unless the arrangement is breached and required notices have been given.
  • Hardship arrangements will be confirmed in writing within 2 business days of agreement.

9. Complaints

  • Complaints about credit management or credit reporting can be lodged with IPSTAR under our Complaint Handling Policy, in accordance with TCP Code Ch 8 and CR Code 2025 clause 21.
  • IPSTAR will acknowledge complaints within a reasonable period and provide a written response within 30 days, unless impracticable.
  • Customers may escalate unresolved complaints to:
    • Telecommunications Industry Ombudsman (TIO) — 1800 062 058, www.tio.com.au
    • Office of the Australian Information Commissioner (OAIC) — 1300 363 992, www.oaic.gov.au

10. Review

This Policy will be reviewed annually or earlier if required due to changes in:

  • The TCP Code C628:2012;
  • The Financial Hardship Standard 2024;
  • The Privacy Act 1988 (Cth); or
  • The Privacy (Credit Reporting) Code 2025.