1. About this policy

The Trustee for Graynell Unit Trust (ABN 80 871 509 522), trading as Atherton Tablelands Law (we, us, our), respects your privacy and is committed to keeping your personal information safe.

This policy explains what personal information we collect, why we collect it, how we hold and use it, who we share it with, and how you can access it, correct it, or make a complaint. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

As a law firm providing services such as property conveyancing, wills and deceased estates, family law, native title, maritime and fishing, mining and resources, we are also a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). This means the Privacy Act applies to the personal information we handle in connection with those obligations, and it is one of the reasons we maintain this policy.

This policy operates alongside, and does not reduce, our professional duty of confidentiality to our clients.

2. The kinds of information we collect and hold

Depending on your matter, we may collect information such as:

• Your name, contact details, address and date of birth
• Identification documents (for example, a driver licence or passport) and the details recorded on them
• For companies and trusts, details of directors, shareholders, trustees, beneficiaries and beneficial owners
• Information about your legal matter, including documents and correspondence you provide to us
• Financial information relevant to your matter or a transaction, such as bank account, loan and settlement details
• Payment and billing information
• If you apply to work with us, information about your work history and qualifications

Sometimes we may need to collect sensitive information, such as health information or criminal history, where it is relevant to your legal matter. We only collect sensitive information with your consent, or where the law otherwise permits or requires us to.

3. How we collect your information

Most of the information we collect comes directly from you, for example when you:

• Contact us by phone, email or through our website
• Meet with us at our office, or speak with us by telephone appointment
• Complete forms or provide documents and instructions

We may also receive information from other people and organisations involved in your matter, including courts and tribunals, government agencies, other lawyers, barristers, experts, real estate agents, banks and financiers. We also obtain information from publicly available registers and search providers, such as title, company and identity verification searches.

4. Identity verification and our anti-money laundering obligations

For certain services, including buying, selling or transferring real estate and buying or selling a business, the law requires us to verify your identity before we can act for you. As a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth):

• We must collect and verify identity information about you and, where you act for a company or trust, about its beneficial owners
• We must screen the parties to certain transactions against sanctions and other regulatory lists
• We must keep records of these checks for seven years
• We may be required to report certain matters to AUSTRAC, the Australian anti-money laundering regulator. In some circumstances the law prevents us from telling you that a report has been made

We do not keep copies of your full identity documents for longer than we need them. Once your identity has been verified and the required records made, we take reasonable steps to destroy or de-identify copies of identity documents we no longer need.

5. Why we collect, hold, use and disclose your information

We collect, hold, use and disclose your information so we can:

• Provide legal advice and services, and communicate with you about your matter
• Verify your identity and meet our anti-money laundering obligations
• Prepare documents and manage your file
• Send invoices and receive payments
• Meet our legal, professional and regulatory obligations
• Run our practice, including accounting, insurance, information technology and record keeping
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We will not use or disclose your information for any other purpose unless you consent, you would reasonably expect it, or the law permits or requires it.

6. Direct marketing

From time to time we may send you updates or information about our services, including by email or through our social media pages. You can opt out at any time by contacting us or using the unsubscribe option in any message we send. We do not provide your information to anyone else for their marketing purposes.

7. Who we share your information with

We only share your information when it is necessary for your matter or for running our practice. Depending on your matter, we may share information with:

• Courts and tribunals
• Barristers, expert witnesses and other lawyers involved in your matter
• Government agencies and regulators, including AUSTRAC, the Queensland Law Society and the Legal Services Commission, where required
• Banks, financiers and settlement platforms involved in a transaction
• Our insurers, auditors and professional advisers
• Service providers who help us run our practice, such as our practice management, document, search and communication software providers, who are required to keep your information confidential

We do not sell your personal information.

8. Disclosure of information overseas

We use secure cloud-based software to run our practice, including our practice management, document, search and communication systems. Some of these providers may store or process information in secure data centres located outside Australia, including in the United States. It is not practicable for us to list every country in which information may be held.

Where information is held overseas, we take reasonable steps to ensure the provider protects it in a way that is consistent with the Australian Privacy Principles.

9. How we hold your information and keep it secure

We take reasonable steps to keep your information secure. This includes:

• Secure, access-controlled computer systems and cloud-based software
• Password protection and staff access limited to those who need it
• Locked storage for paper files
• A data breach response plan, so we can act quickly if something goes wrong. If a data breach is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme

We keep your information for as long as we need it to provide our services and to meet our legal and professional obligations, including the record keeping periods that apply to law firms and the seven year period that applies to anti-money laundering records. When we no longer need your information, we take reasonable steps to destroy it or de-identify it.

10. Dealing with us anonymously

You can contact us with a general enquiry without identifying yourself. However, we cannot provide legal services anonymously or under a pseudonym, because we need to identify our clients to act for them, and for many of our services the law requires us to verify your identity.

11. Our website

If you visit our website, it may collect basic information such as traffic and usage data through cookies and analytics tools. We use this information to improve our website. You can disable cookies in your browser settings, although parts of the website may not work as intended if you do. Our analytics providers may process this information outside Australia.

12. Accessing and correcting your information

You can ask to see the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date or incomplete. Please put your request in writing to our office. We will respond within a reasonable time, usually within 30 days.

There is no charge for making a request, although we may charge a reasonable amount for providing access, such as copying costs. In limited circumstances the law allows us to refuse access, for example where the information is subject to legal professional privilege. If we refuse your request, we will tell you why in writing and how you can complain about that decision.

13. Questions and complaints

If you have a question about this policy, or you believe we have mishandled your personal information, please contact us using the details below. We will acknowledge your complaint within seven days, investigate it, and give you our response within 30 days.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

14. Changes to this policy

We may update this policy from time to time. The latest version will always be available on our website and, free of charge, from our office.

15. Contact us

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

Office: 13A Herberton Road, Atherton Qld 4883

Postal: PO Box 101, Atherton Qld 4883

Phone: (07) 4091 5388

Fax: (07) 4091 5205

Email: atherton@tablelandslaw.com.au

Website: www.tablelandslaw.com.au

Our lawyers are admitted in Queensland and hold current practising certificates issued by the Queensland Law Society.