Privacy collection notice for customer due diligence
This privacy collection notice from Andrew Douglas Solicitors outlines why we collect your personal information, what we collect, how we collect it and who we share it with.
Why we need to collect your information
We collect your personal information to comply with the ‘Customer Due Diligence’ requirements in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). This includes to, for example:
- establish and verify your identity before providing certain services to you or the person you are acting on behalf of
- assess and manage potential money laundering, terrorism financing, proliferation financing risks or related compliance risks associated with the provision of our services
- make reports required by law under the AML/CTF Act
- meet record keeping obligations under the AML/CTF Act.
What personal information we collect
The types of personal information we collect for Customer Due Diligence include, for example:
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- your full name, date of birth, residential address
- photo ID and unique identifier, such as a passport or driver’s licence number
We also collect the following sensitive information, for example: whether you are a member of any political associations, professional or trade associations may be used to verify your occupation or determine whether you are a politically exposed person.
How we collect your information
We will generally collect your personal information by directly asking you to complete an Onboarding form, for example:
- using a third party identity verification service such as Australia Post or InfoTrack to collect personal identification information on your behalf, if you cannot attend one of our offices
- using InfoTrack software to assist with our record keeping and compliance obligations.
- Checking other sources such as from registers of companies, trusts, or public records (such as court records, regulatory filings, land registries), financial institutions or professional intermediaries.
Who we may share your information with
We may also share your personal information with AUSTRAC to meet our legal and regulatory obligations under the AML/CTF Act or the AML/CTF Rules.
What happens if we cannot collect your information
If you do not provide us with your personal information, we may not be able to verify your identity and provide you (or the person you are acting on behalf of) with the services you have requested.
Your privacy rights and our privacy policy
Our Privacy Policy contains further information about how we will handle your personal information and how you can access and correct your personal information. It also outlines how to lodge a complaint and how that complaint will be managed if you are concerned about how we handled your information.
How to contact us about your privacy
If you have any queries regarding this Privacy Policy, please contact our office using the contact details on our website or on the bottom of our emails or correspondence.