PRIVACY COLLECTION NOTICE
FOR CUSTOMER DUE DILIGENCE

 

This notice is provided by SRM Residential in accordance with the Australian Privacy Principles (APP 5) and the guidance of the Office of the Australian Information Commissioner (OAIC). Please read this notice before providing your personal information.


Important — How your information is handled
SRM Residential collects and holds basic contact and transaction information (such as your name, address, phone number and email) in the ordinary course of conducting a property sale. This is separate from, and in addition to, the identity verification process described in this notice.
 
For AML/CTF identity verification purposes, SRM Residential does not retain copies of your identity documents or verification data. That information is collected by SRM Residential solely to submit to our authorised identity verification provider, MemberCheck, which conducts the required checks on our behalf. SRM Residential does not hold AML/CTF verification data in its own systems beyond what is necessary to facilitate that process.


Why We Need to Collect Your Information
We collect your personal information to comply with our Customer Due Diligence (CDD) obligations under the AML/CTF Act. This includes to:

  • Establish and verify your identity before providing real estate services to you, or to the person you are acting on behalf of
  • Assess and manage potential money laundering, terrorism financing and proliferation financing risks associated with our services
  • Make reports required by law, including to AUSTRAC
  • Meet our record-keeping obligations under the AML/CTF Act and AML/CTF Rules 2025

 

What Personal Information We Collect
Transaction information (collected and held by SRM Residential for the purposes of conducting a property sale):

  • Full legal name, residential address, phone number and email address
  • Entity details where you are acting on behalf of a company, trust or other entity

 

AML/CTF identity verification information (collected by SRM Residential and submitted to MemberCheck for verification processing — not retained by SRM Residential):

  • Date of birth
  • Photo identification details, such as your passport number or driver’s licence number and state of issue
  • Beneficial ownership details where you are acting on behalf of a company, trust or other entity
  • Source of funds or source of wealth, where required by your risk profile

 

Sensitive information (collected only where required for AML/CTF compliance, submitted to MemberCheck):

  • Whether you hold or have held a prominent public or political position (to assess whether you are a Politically Exposed Person)
  • Information relevant to sanctions screening and adverse media checks

 

How We Collect Your Information
We collect your personal information in the following ways:

  • Directly from you at the time of engagement, either in person, electronically, or through our online portal
  • By submitting it directly to MemberCheck, our authorised identity verification provider, which processes it on our behalf and is bound by equivalent privacy obligations
  • From public records such as land registries, court records, company registers and regulatory filings
  • From financial institutions or professional intermediaries involved in your transaction

 

Biometric verification
If biometric identity verification is used as part of the MemberCheck process, your consent will be sought beforehand. An alternative verification pathway is available if you do not consent to biometric processing.

 

Who We May Share Your Information With
Your information is submitted to the following parties for the purpose of AML/CTF compliance:

  • MemberCheck (our appointed identity verification provider) — your information is submitted directly to MemberCheck to perform PEP screening, sanctions checks, adverse media checks and identity document verification on our behalf
  • AUSTRAC — to meet our legal reporting obligations under the AML/CTF Act
  • Other entities in our AML/CTF reporting group, where applicable
  • Regulatory or law enforcement agencies, where required by Australian law


Tipping-Off Prohibition
We are prohibited by law from telling you if a Suspicious Matter Report (SMR) has been or may be submitted in relation to you or your transaction. Access to information connected with an SMR may be restricted under the AML/CTF Act.

 

What Happens If You Do Not Provide Your Information
If you do not provide the required personal information, we may be unable to verify your identity. In that case, we will be unable to provide you (or the person you are acting on behalf of) with the requested real estate services.


Your Privacy Rights
You may request access to or correction of the personal information collected about you, subject to any restrictions imposed by the AML/CTF Act. Our full Privacy Policy is available on our website and upon request at our office. It contains further information about how your personal information is collected and used, and how to lodge a complaint.
https://srmresidential.com.au/privacy-policy/