Privacy collection notice for customer due diligence

This privacy collection notice from Kin Lawyers Pty Ltd ABN 69 636 788 595 (“Kin Lawyers”, “we”, “us”) outlines why we collect your personal information, what we collect, how we collect it and who we share it with.

This privacy collection notice outlines, in respect of our client due diligence processes in line with requirements in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), why we collect your personal information, what information we collect, how we collect it and who we share it with.

Clients and any persons providing personal information to Kin Lawyers on a client’s behalf must ensure to obtain all necessary consents from and provide all necessary notices to any individuals whose information will be provided to or collected by Kin Lawyers, including promptly distributing this privacy collection notice to those individuals.

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) and regulations and rules under it (“AML/CTF Regime”). This includes to:

  • establish and verify your identity (and if required, the identity of other related parties and/or associated organisations/entities connected with you and related parties) before providing certain services to you or the person or organisation you are acting on behalf of;
  • assess and verify further information from you (and if required, from other related parties) – and/or or via third party data suppliers – as may be required, including in respect to beneficial ownership or control of entities (incoming and/or outgoing), sources of relevant funds/assets, and other factors relevant to undertaking due diligence and managing potential money laundering, terrorism financing, proliferation financing risks or related compliance risks associated with the provision of our services; and
  • meet our reporting and record keeping obligations required by law under the AML/CTF Regime.

What personal information we collect

The personal information we collect to enable us to comply with our AML/CTF obligations differs from person to person (and organisation) depending on the circumstances and the type of identity documentation verified.  We may collect the following types of personal information in connection with client due diligence from and in relation to you (and if required, from and in relation to other related parties and/or associated organisations/entities connected with you and related parties and your services):

  • full name, gender, date and place of birth, country of residence and nationality, location details, and contact details (address, email and phone);
  • current and prior businesses, industries, occupations, company affiliations, roles, titles, biography, education and unincorporated businesses;
  • current and prior directorship details, including director ID numbers and any disqualification;
  • current, prior and incoming roles as a controller and/or beneficial ownership of an entity/organisation;
  • family and other relationships;
  • photo ID and unique identifier such as a passport, national ID or driver’s licence number, relevant expiry dates and class where applicable, and other information identifiable from scanned ID documents such as photographs and organ donor status;
  • information obtained from sanctions’ lists, politically exposed persons’ lists, monitoring services, screening services, fraud-prevention services and document verification services;
  • services and transactions obtained, offered and supplied including usage history, including information about the time, place, and circumstances of our interactions with you;
  • information regarding source of wealth, source of funds and the nature and purpose of the business relationship or transaction, as applicable; and
  • other information about you available in public records or that you provide to us or our third party service providers.

We also collect the following sensitive information:

  • details of your political affiliations, opinions and exposure; membership of or involvement with political, professional or trade associations; religion and religious beliefs; sanctions and unlawful activities, including terrorism and other criminal activities.

We may infer information about you from your engagement with us and your activities. We may conduct ongoing monitoring of transactions and client information to comply with our obligations under the AML/CTF Regime.

How we collect your information

We will generally collect your personal information:

  • directly from you, your employer, or the person or entity you beneficially own or are acting on behalf of;
  • via InfoTrack platform databases including their identity verification and screening service and third party data suppliers including but not limited to Australian Securities and Investment Commission (ASIC) company searches, Personal Property Securities Register (PPSR) searches, Australian Financial Security Authority (AFSA) bankruptcy searches, Criminal History Checks supplied by the Australian Criminal Intelligence Commission (ACIC) and the National Police Checking Service (NPCS), Verification of Identity check supplied by the Commonwealth Government Document Verification Scheme (DVS), and state-based land registry services – InfoTrack’s Privacy Policy is available at this link:

https://www.infotrack.com.au/wp-content/uploads/InfoTrack-AU-Privacy-Policy-12-March-2026.pdf

  • from government databases such registers of companies, trusts, or public records (such as court records, regulatory filings, and land registries including SA Land Services); and
  • from public search engines.

Who we may share your information with

We may disclose your personal information to third parties to assist us with AML/CTF obligations including collection, screening, identity verification and storage. We may also disclose your personal information to third party external service providers so they can provide us with services related to our business, for example mailing services, IT services, cloud services, data analytics and risk assessment services, data storage/hosting or archive services. While Kin Lawyers is an Australian firm, some of the aforementioned third parties may be located overseas, and your personal information may be disclosed to such overseas locations which may include but are not limited to New Zealand, countries of the European Union, the United Kingdom, Singapore, India, the United States of America, and Japan.

We may also share your personal information with AUSTRAC to meet our legal and regulatory obligations under the AML/CTF Regime.

What happens if we cannot collect your information

If you do not provide us with sufficient personal information, we may not be able to verify your identity, to comply with our obligations under the AML/CTF Regime and to provide you (or your employer or the person you beneficially own or are acting on behalf of) with the services you have requested. The amount and type of information that is sufficient to verify your identity and/or enable us to comply with our AML/CTF obligations may differ depending on the particular circumstances.

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 is available at this link:

  • https://kinlawyers.com.au/privacy-policy-for-aml-ctf-obligations/

How to contact us about your privacy

You can contact our Privacy Officer by:

  • email to privacy@kinlawyers.com.au
  • by telephone 08 7076 9333 and requesting to speak to our Privacy Officer
  • by mail to PO Box 1137 Glenelg South SA 5045 for attention of the Privacy Officer

Date reviewed: 1 July 2026

Liability limited by a scheme approved under Professional Standards Legislation.

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