Code of Practice
This document is a Code of Conduct for Intercoll and its staff to provide assurance and accountability of best practice behaviour when carrying out its business as a debt recovery and investigation practice.
Intercoll is committed to the following underlying principles in the conduct of its business:
- To treating debtors fairly, in a professional and respectful manner.
- To being transparent in its dealings with debtors and their representatives.
- To ensuring clear, effective and appropriate policies and processes for engaging with debtors and that staff are trained in these policies and procedures.
- To engaging with stakeholder organisations to continuously improve standards and practice.
A copy of this Code will be readily available and displayed at Intercoll’s offices and published on its website.
Copies are available on request.
In the day to day conduct of its business, Intercoll will:
- Conduct its business lawfully and comply with all relevant legislation and regulation of the industry.
- Ensure staff and all authorised representatives are trained to undertake their collection activities in accordance with this Code including ongoing training in respect of best practice.
- Ensure that its identity is clearly disclosed by staff and/or representatives at all times, including contact details, and that its business is conducted in a way that will not confuse or mislead debtors, their representatives or any member of the public or imply an association or connection with any other organisation or person that does not exist.
- Use plain English in all communications.
- Treat all debtors with respect and fairness by ensuring compliance with the company’s approved standards for approaching and communicating with debtors and their representatives when undertaking debt collection.
When communicating with debtors or their representatives or advisors, Intercoll will:
- Communicate in a courteous and respectful manner using plain language.
- Where it is identified as appropriate by the staff member or collecting agent, recommend or provide information to debtors about third party agencies that may provide external advice and/or support.
- Where applicable and reasonably possible, make all communications using any specified preferred method.
- Ensure telephone calls and physical visits are conducted at reasonable times and intervals as set out in company procedure, the size of the debt and previous conduct of the debtor (e.g. breach of court order, change of identity and address).
- Explain Intercoll’s right to take further action, including initiating court proceedings, and identify its right to seek additional costs for such action (but not imply that action is underway or has been approved where that is not the case).
- Respond to all requests for information in a timely and reasonable manner, including to duly authorised representatives.
Privacy and Confidentiality
Intercoll recognises the importance of ensuring the right to privacy and confidentiality about a person’s financial affairs and in order to protect these rights it will:
- Not leave phone messages that disclose the nature of the call or any details of the debt or debtor’s personal information.
- Not discuss the debt with any person other than the identified debtor unless it has been authorised to do so by the debtor.
- Not disclose any information to any person in the course of trying to locate a debtor that might lead to identification of the purpose of any contact.
- Not unnecessarily intrude at a person’s place of work in a manner that could cause distress or embarrassment or jeopardise the person’s employment relationship.
When visiting a residential or work address, Intercoll will:
- Act in accordance with the privacy principles in the Privacy Act 1993 and the standards set out above.
- If calling at a work address, take care not to interfere with the person’s conduct of their employment duties.
- Clearly identify who they are prior to engaging in any discussion.
- Clearly identify the purpose of the visit.
- Advise that for the assurance of both parties all conversations are recorded.
- Provide information about Intercoll, including FAQs, as approved by the business from time to time and allow the person time to read such information.
- Leave copies of any documentation being relied upon or that has been signed with the person.
- Leave when requested to do so.
Arrangements to Pay
Intercoll will work with debtors and stakeholders to accommodate a reasonable and practical resolution, including:
- Agreeing to budgeting projections to identify residual income available for debt reduction, taking into account reasonable expense allowances (provided the debtor is open to providing information about proof of income, outgoings and other information that may be relevant to an accurate assessment of their financial position).
- Fair consideration of a reasonable offer to satisfy the debt through regular instalments or lump sum repayment.
- Automatic acceptance of repayment of $10 per week in respect of debts less than $5000 or $20 per week for debts greater than $5000 where such repayments are made through a voluntary WINZ or wage deduction (subject to any required approvals by Work and Income, MSD and/or the employer) if requested.
- Suspension of all collection and recovery action for a reasonable time.
- Suspension of all communication while any repayment plan is in place and obligations are met, subject to any legal disclosure obligations.
Intercoll will assist debtors who are facing financial difficulty through genuine hardship (provided the debtor is willing to provide information and/or proof of their circumstance e.g. illness, redundancy).
This may include:
- Referrals to not-for-profit financial mentoring and/or budgeting services for independent advice and support.
- Reduction in repayment amounts and/or a postponement of the payment period in the event of specific financial hardship due to Covid-19 (provided the debtor is willing to provide information and/or proof of their circumstance e.g. reduced income, reduced wages, illness, redundancy).
- Postponement of any collection or recovery action.
- Reduction in repayment amounts and/or a postponement of the payment period.
- Reduced settlements where possible.
Complaints and Engagement
Intercoll is committed to continuous improvement and ongoing engagement with community organisations assisting debtors manage their financial liabilities. In this context it undertakes to manage complaints promptly and to engage and consult with community services and budgeters with the intention of reasonably addressing issues relating to responsible financial accountability and genuine hardship.
In the first instance any formal complaints, including complaints arising from alleged breaches of this Code, should be addressed to:
PO Box 21654
Telephone: 09 8277701
For urgent matters or to discuss in person, calls can be made to the number above. However, for audit and control purposes all complaints must be registered in writing at some stage.
Intercoll will, from time to time contact budgeting services to discuss issues relating to maintaining best practice in the debt collection industry.
Status of the Code
This Code has been prepared by Intercoll for the exclusive use of Intercoll in the management of its internal assurance and best practice procedures.
Breach of the Code is not in any way an admission of liability or breach of legal obligation by Intercoll and the Code cannot be used by third parties to support any action against the company or its employees or representatives.
Intercoll has the right to amend the Code at any time.