Privacy collection notice for customer due diligence
This privacy collection notice from Tetlow Legal Pty Ltd ACN 646 293 272 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:
- 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; and
- meet record keeping obligations under the AML/CTF Act.
What personal information we collect
We collect the following types of personal information:
- your full name, date of birth, residential address; and
- photo ID and unique identifier, such as a passport or driver’s licence number.
We also collect the following sensitive information:
- 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 one of the following methods:
- directly;
- through a third party identity verification service (InfoTrack Pty Limited ABN 36 092 724 251 and its Australian subsidiaries) in which you will receive an email with a link to complete various forms online to meet our obligations under the AML/CTF Act; and/or
- from 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
Information is disclosed to third-parties such as, InfoTrack and Smokeball, to assist with AML/CTF obligations including identity verification and storage.
These entities are located in Australia, however, their servers may be located in Australia, the United Kingdom and the USA.
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. Our Privacy Policy can be found on our website: www.tetlowlegal.com.au.
How to contact us about your privacy
If you have any questions about our Privacy Policy or wish to discuss any concerns, please contact us by post, email or phone via the below details:
Tetlow Legal Pty Ltd
GPO Box 1569, Canberra ACT 2601
(02) 6140 3263