Privacy & AML/CTF Notice

This notice explains how SJG Legal Pty Ltd ("we", "us", "our") collects, uses, stores, and discloses your personal information when we act for you, including in conveyancing matters.

In the course of acting for you, we may collect:

• Your full name (including previous names), contact details, date of birth, occupation, and copies of identification documents.
• Property and transaction details.
• Financial information relevant to the matter (e.g. loan details, source of funds/source of wealth).
• Information required to verify your identity.
• Information about any beneficial owners or controlling persons (e.g. if you are acting for or on behalf of a company, trust, or other entity).
• Information about the source of funds to be used for your transaction.
• Information relevant to assessing whether you are a politically exposed person.
• Correspondence between you, us, and other parties.

We usually collect your personal information directly from you, for example, when you provide identification documents, complete our Intake Forms, or communicate with us.

We may also collect information from:

• Real estate agents and the other party's solicitor or conveyancer.
• Your financial institution or mortgage broker.
• Government, public registers and publicly available sources (e.g. NSW Land Registry Services, councils, ASIC).
• Identity verification providers and search agents.
• Other third parties involved in your transaction.

We collect and use your personal information to provide conveyancing/legal services and to comply with our obligations under applicable laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

This includes to:

• Provide legal services and act for you in your matter, and administer our engagement with you, including billing and maintaining client records.
• Communicate with you and other parties involved in the transaction.
• Prepare and lodge documents with relevant authorities (e.g. NSW Land Registry Services, Revenue NSW).
• Verify your identity, and the identity of any beneficial owner, controlling person, or person acting on your behalf.
• Understand the purpose and nature of the transaction, including understanding the source of funds/source of wealth, and assessing and managing money laundering and terrorism financing risk.
• Conduct ongoing monitoring of our business relationship with you, including reviewing transactions and updating information where required on a risk-based basis.
• Determine whether you are acting on behalf of another person or whether funds are being provided by a third party.
• Assess the level of risk associated with your matter and apply appropriate client due diligence measures.
• Meet our reporting obligations to the Australian Transaction Reports and Analysis Centre (AUSTRAC), where applicable.

We may disclose your personal information to:

• AUSTRAC, or other government and regulatory bodies, where required or authorised by the AML/CTF Act or AML/CTF Rules.
• Identity verification providers engaged to assist with our customer due diligence obligations.
• PEXA/electronic conveyancing platforms, the other party to the transaction and their legal representative, search agents, your lender and/or broker, our professional indemnity insurer, and our IT and document storage providers.
• Our AML/CTF reporting group, if applicable (e.g. associated entities subject to a joint AML/CTF program).
• Government, regulatory bodies and professional bodies, such as Revenue NSW, Land Registry Services, and the Law Society of NSW.

We will not sell your personal information.

In some circumstances, we may be legally required to collect some or all of the above information before acting for you.

If you do not provide us with the personal information we request, we may be unable to act for you, or may need to cease acting for you, in order to comply with our legal obligations.

We may also be prohibited by law from telling you if we have made a report to a regulatory authority (including AUSTRAC), as doing so may constitute a "tipping off" offence under the AML/CTF Act.

We store personal information in secure physical and electronic file management systems.

We take reasonable steps to protect your information from misuse, loss, unauthorised access, or disclosure.

We retain client files for the period required by law and professional obligations, after which they are securely destroyed or de-identified.

The AML/CTF Act restricts what we can tell you about certain aspects of our compliance activities.

We are not able to disclose to you whether we have formed a suspicion about a matter, or whether we have made, or are considering making, a report to AUSTRAC, as doing so may constitute a "tipping off" offence under the AML/CTF Act.

We do not typically disclose personal information overseas.

If this becomes necessary (for example, where a party to the transaction is overseas), we will inform you (where practicable), and take reasonable steps to ensure your information remains protected.

You may request access to, or correction of, the personal information we hold about you, subject to exceptions under the Privacy Act 1988 (Cth) and the AML/CTF Act (including the tipping-off restriction described above).

If you have a concern about how we have handled your personal information, please contact us using the details below.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

If you have any questions about this notice or how we handle your personal information, please contact:

SJG Legal Pty Ltd
ABN: 41 678 739 510

Phone: 0478 839 229
Email: contact@sjglegal.com.au
Address: 288 Forest Rd, Hurstville NSW 2220, Australia