A series of three articles appeared last week:
First we had.
Afterpay accessing electoral roll data under laws designed to target terrorism, money laundering
By Eryk Bagshaw
24 January 2019 — 12:01am
The confidential electoral roll data of more than 16 million Australians is being used by buy now, pay later providers, debt collectors, betting agencies and marketing firms to identify individual consumers.
The Age and Sydney Morning Herald can reveal data obtained by debt-collectors and data marketing firm Illion, formerly known as Dun & Bradstreet, is used by $4 billion stock market darling Afterpay and other providers to match identities to addresses as it processes customers at thousands of suburban shops including David Jones, Officeworks and Nike.
The electoral data, designed to be used under the Anti-Money Laundering and Counter-Terrorism Financing Act, is accessed by Afterpay and other firms via Perceptive Communications, a wholly owned subsidiary of Illion.
Electoral data contains the most accurate information on the addresses and identities of Australians and is used by the Australian Federal Police, Australian Securities and Investments Commission and the Director of Public Prosecutions to track offenders and suspects.
But under legislation changes published in November, Perceptive and its parent company Illion, along with betting agency Betfair and three other companies including marketing giant ACXIOM, were also granted access to the data on millions of Australian voters as part of the anti-money laundering and counter-terrorism financing push.
ACXIOM, which says "it solves critical use cases for omnichannel, people-based marketing," and Betfair, an online gambling company, have no relationship with Illion or Afterpay.
The Australian Electoral Commission would not comment on whether the use of the data by the companies was appropriate as the anti-terrorism and money-laundering legislation was administered by the Attorney-General's Department. The Attorney-General's Department said Home Affairs was responsible for the legislation. Home Affairs did not respond to requests for comment.
Using electoral data for commercial purposes attracts a fine of up to 1000 penalty units - equivalent to $210,000 - according to the Australian Electoral Commission website. The AEC has strict restrictions on who can access the data, including members of parliament, political parties, approved medical researchers, and public health programs.
Illion initially denied it used electoral data and did not respond to requests for comment about what data it did provide to Afterpay. But in a subsequent statement it said for customers with "[anti-money laundering obligations] we may access electoral data to verify identities."
"We do not disclose details of any commercial arrangements with our customers," the spokesman said.
Afterpay said it did not access the data directly, use the electoral data in its algorithm or for commercial purposes and that it was used as part “of external identification purposes.”
The Illion-obtained electoral data is passed on to Afterpay and combined with other external data bases including billing and shipping addresses, debit or credit card information, IP addresses and phone numbers.
"Decisions are made on better data and on a real-time basis," said Afterpay economic adviser Craig Emerson. "The banks, traditional credit products and even others in the sector either don’t have the ability or the inclination to undertake checks of this nature."
Then we had this:
Majority of companies with access to electoral roll are global marketing firms
By Eryk Bagshaw
25 January 2019 — 12:01am
The Morrison government has warned the security of electoral data "is fundamental to our democracy", as new details reveal four of the five firms granted access to the names and addresses of millions of Australian voters run massive digital marketing operations.
The Sydney Morning Herald and The Age on Thursday revealed that $4 billion stock-market darling Afterpay and other financial services firms were using the electoral roll services of debt-collection agency Illion to help it identify customers and protect against fraud, money laundering and terrorism.
Four of the five firms granted access to the names and addresses of millions of Australian voters run massive digital marketing operations. Credit: Karleen Minney
But it has emerged that along with Illion, formerly known as Dun & Bradstreet, and marketing giant ACXIOM, multinationals Experian and Global Data were also given access to Australian electoral rolls as part of amendments to electoral legislation published in November.
The fifth, Equifax, was responsible for a breach of personally identifiable information of over 145 million people in the US in 2017 and was convicted of misleading, deceptive and unconscionable conduct by the Australian Federal Court in October.
All have identity and credit check platforms - used by financial service providers such as Afterpay, Zip and banks against fraud, money laundering and terrorism financing - but also run marketing operations that sell detailed data to businesses in Australia and around the world.
Experian describes itself as "a leading global information services company, providing data and analytical tools to our clients".
It says it will help customers "acquire more prospects that fit your most profitable customer profile, gain data-driven insights and leverage analytics and insights for deeper audience intelligence".
ACXIOM Australia, which has renamed itself as "Live Ramp,"said in a note to clients last year that it was realigning its business.
"We are looking forward to empowering our clients to harness the benefits of people-based marketing, and as a result, better serving the evolving needs of the consumer," it said.
It has not responded to multiple written requests for comment, the phone number at its Australian head office in Barangaroo has been disconnected and an auto-reply email said "data monetisation glory awaits!"
Equifax, which is used by Afterpay buy-now-pay later rival Zip to run credit checks on hundreds of thousands of customers across shops such as Rebel, Fantastic Furniture and Best & Less, was pursued by the Australian Competition and Consumer Commission for misleading, unconscionable and deceptive conduct last year.
It paid a $3.5 million fine in October after the Federal Court found it charged customers to receive their credit reports when they were available online for free. In 2017, it had the records of 145.5 million - 99 per cent of its US user base - hacked in a breach described by the US House of Representatives committee as "entirely preventable".
A spokeswoman for the company, listed as a prescribed authority under its former name of Veda, said it had specific confidentiality, security and statutory obligations to maintain the security of its information, and "treats the safeguarding of data with the utmost priority".
Global Data, which has not responded to a request for comment, says on its website that its marketing platform Quester will help clients understand their customer quickly and easily.
Lots more here:
Third we had:
Details of 1 million Australians added to giant marketing database without their knowledge
By Eryk Bagshaw
26 January 2019 — 12:00am
More than 1 million Australians have had their name and address added to the electoral roll and then automatically passed to global marketing giants without their knowledge.
Direct enrolment laws passed by Parliament in 2012 meant Australians no longer had to register on the electoral roll to have their details entered, with information of workers and school students scanned from drivers licences, Centrelink and records from the Board of Studies in each state.
The electoral roll has since been handed over to credit-check operators for identification purposes designed to help financial services firms such as banks, Afterpay and Zip, to run fraud, anti-money laundering and anti-terrorism checks, but four of those identity firms are now running global marketing operations using data analytics.
No government body has been able to advise if anyone is monitoring the companies for breaches of the electoral act, which carries fines for using the data in commercial operations, or if they are monitoring the separation of data between the companies' identification and marketing arms.
The Sydney Morning Herald and The Age revealed this week that AXCIOM, Experian, Global Data and illion (formerly known as debt collectors Dun & Bradstreet) all have access to the electoral roll as "prescribed authorities". In their secondary businesses, each boasts of their ability to provide marketing data analytics on millions of Australians to their clients but maintain they are in full compliance with the privacy act and do not use the data for marketing purposes.
AXCIOM and Global Data have not responded to multiple requests for comment. An auto-reply email from AXCIOM said "data monetisation awaits!"
The only non-marketing firm among the group, US credit check giant Equifax, had the records of 145.5 million hacked in a breach in 2017 was fined $3.5 million by the Federal Court last year for misleading, deceptive and unconscionable conduct.
The Australian Electoral Commission advises people who are going to be automatically enrolled by mail, but those who want to opt out have 28 days to respond or they are automatically signed up to a database that contains information on 16 million Australians. More than 1.5 million Australians who were eligible to vote - but not on the electoral roll - are likely to have been added since the laws passed.
School students as young as 16 have been caught up in the data transfer, with more than 18,846 people aged 16 and 17 provisionally on the electoral roll as of December 31.
More here:
I have had a look at the Australian Privacy Principles and this one stands out:
APP 6 – use and disclosure of personal information
APP 6 outlines the circumstances in which an agency may use or disclose the personal information that it holds about an individual.
APP 6 introduces a limited number of new exceptions to the general requirement that an agency only uses or discloses personal information for the purpose for which the information was collected. These include where the use or disclosure is reasonably necessary:
- to assist in locating a missing person
- to establish, exercise or defend a legal or equitable claim, or
- for the purposes of a confidential alternative dispute resolution.
Here is the link.
Hard to see just why the Aust. Electoral Office is playing footsie with Marketing companies and credit providers on that basis. The Electoral Role would appear to exist to run elections – not this other stuff.
David.
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