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Correspondence with Indue: #Cashless Welfare card
I recently emailed a list of questions to Indue after reading their cashless welfare card Conditions of Use.
Questions for Indue
I write to you with questions based on the document at https://indue.com.au/wp-content/uploads/Conditions-of-Use.pdf Why do you not pay interest on the funds kept on Indue cards? How was the list of restrictions you impose on card holders drawn up?
These restrictions include:
* refusal to pay interest on savings;
* preventing joint banking;
* refusing the ability to pay down other credit cards;
* refusing the ability to set up direct debits;
* refusing chargeback rights provided with normal bank card purchases;
* construction of merchant whitelist/exclusion list.
Who were the stakeholders in the decision making process to create the above list of punishments and where is the documentation to provide accountability to the public about how this list was developed?
Can you please list the datasets that you share with other organisations and the organisations that you share this data with?
Why do you collect information about taxi rides taken by people using your debit card? What information do you collect about journeys taken by card holders?
Why are Indue account holders required to provide you with ‘external account information’?
Is it the case that you supply card holder transaction history with the Commonwealth Government? (p64)
What is the name of the ‘overseas service provider’ that you share card holder information with? (p65) What data does the Indue DCT App collect? (p71)
thank you for your time Rosie Williams BA (Sociology) whistleblower.network
Here is their reply. I have coloured text in red where I have concerns.
5:02 PM (2 minutes ago) to me
Dear Ms Williams
Thank you for your questions regarding the Cashless Debit Cards issued by Indue in connection with the Commonwealth Government’s Cashless Debit Card Trial.
Account Restrictions and Interest on Funds
The restrictions associated with the Cashless Debit Cards and Accounts including the decision to offer fee-free accounts and not to pay interest on the funds in accounts were decisions of the Commonwealth. Any questions related to the decision making process surrounding the Cashless Debit Card Trial should be directed to the Department of Social Services at email@example.com.
Although the Department of Social Services is best placed to answer your questions regarding the restrictions, we take this opportunity to clarify the following with respect to the restrictions noted in your correspondence:
- chargeback rights that exist for Visa debit cards issued by other financial institutions also apply to the Cashless Debit Cards. Indue encourages anyone who believes that an incorrect or unauthorised transaction has occurred through the use of their Cashless Debit Card to contact Indue’s Customer Service Centre on 1800 710 265;
- cardholders are able to enter into direct debit arrangements with third parties by using their Visa Card number but not their BSB and Account Number; and
- cardholders are able to transfer at least $200 per 28 days from their Cashless Debit Card account to a third party account which may be used to pay down any credit card debt. If cardholders believe that the restrictions in place are causing them financial hardship by preventing them from paying off credit card debt, then Indue recommends they contact the Department of Social Services on 1800 252 604.
Indue only collects and discloses information for the purpose of providing services to cardholders and providing information to the Commonwealth for the purposes of the Cashless Debit Card Trial. The information that Indue shares in the course of providing the services includes details such as a cardholder’s name, date of birth and address as well as transactional information, including the amount of a transaction, where a transaction was undertaken and who the payment was made to or received from. It is essential to provide these details to payment scheme providers so that transactions can be made. In addition to the Commonwealth, in the course of providing the services to cardholders Indue may provide information to:
- service providers who Indue operate the accounts (such as the card manufacturer and Indue’s payment switch);
- payment scheme providers (such as Visa, BPAY and APCA);
- regulatory bodies, government agencies, law enforcement bodies and courts;
- other participants in the financial systems (such as other financial institutions for the purpose of resolving disputes, errors or issues in relation to Accounts); and
- other parties as is authorised or required by law.
Information regarding taxi journeys may be collected to ensure merchants cannot circumvent welfare restrictions.
External account information
There is no obligation on Indue account holders to provide Indue with their external account information. In certain circumstances Indue may request this information from account holders or the Commonwealth so that Indue can facilitate a transfer from an Indue account to a cardholder’s external account. For example, to return any residual funds to a Cashless Debit Card account holder upon the closure of their account.
Provision of transaction history to the Commonwealth
As set out in the Conditions of Use for the Cashless Debit Card (available on our website at www.indue.com.au/dct/cou), Indue shares information collected about cardholders with the Commonwealth. This information may include the cardholder’s address, date of birth, contact details, transaction history and communications a cardholder has had with Indue about their account. This is necessary for the Commonwealth to operate aspects of the trial.
Indue DCT Application
Once the Indue DCT Application has been installed on a device and a card holder has logged into their account, Indue will collect device identification details including DeviceId, DeviceName, DeviceModel, DevicePlatform and DeviceVersion. These device details allow Indue to identify the type of device used by a card holder. These details are necessary for the Application to allow in-application notifications to card holders.
customer service centre
PO Box 523, Toowong QLD 4066
phone 1800 710 265
May 5, 2017 / Rosie / 0