Privacy Policy

Personal information means information or an opinion about an identified individual, or individual who is reasonably identifiable. It does not include information which has been de-identified. This information may include factual information or opinions about you.

Thompson Legal collects a range of personal information, which may include your:

• Name
• Email address
• Signature
• Mobile number
• Landline number
• Home address
• Business address
• Occupation
• Employer
• Date of birth
• Information from identity documents
• Bank account details
• Photographs
• Criminal history
• Educational qualifications
• Employment history
• Other information which may be required to identify you in order to provide our services

We may also collect information to comply with our obligations under the Act and Rules, when conducting our client due diligence. We may need to ask you whether you are a politically exposed person (“PEP”), or a family member or close associate of a PEP. A PEP includes someone who holds a prominent public position in Australia or elsewhere such as a senior role in government, trade union, state-owned enterprises or professional bodies, the courts or the military. We may ask you to provide information about any company, trust or other entity involved in the matter, including its beneficial owners and controllers. In connection with the Act and Rules, we may also be required to ask you to provide us with information about the source of your funds and source of wealth and ask for an update of information during the course of your matter.

We may store your tax file number information in line with the rules relating to tax file number information under the APPs but will not disclose this other than as required or authorised by law. In addition to information from your identity documents, we may also collect and store identification document numbers, expiry dates, your place of birth and country of residence for tax purposes. As well, we may be obliged to collect, store and share details about the nature of the legal service we are providing to you, along with relevant information to assess money laundering or terrorism financing risks.

We may collect sensitive information from you. Sensitive information includes your sexual orientation, racial and ethnic origin, political beliefs, religious affiliation, criminal record and health information.

We collect personal information directly and indirectly. We collect your personal information online or via hard copy, using our electronic platforms and databases, by paper forms, by telephone, by email, by in person attendance and by appointments. While some of the personal information we collect comes from your disclosure to us, there may be situations where we collect your personal information from a third party; not all information we collect from third parties will be authorised by you. There are lawful reasons for disclosure of your personal information without your notice and/or authority.

To protect your personal data from unauthorised access and/or misuse, we use physical and digital security protections along with our internal compliance. Our IT systems are protected by firewalls, secured databases and anti-virus software. Our accounts are protected with complex passwords and require multifactor authentication (MFA). We perform consistent and regular checks to ensure our control, defence and access to personal information is properly protected in line with the APPs. As well, all employees are bound by strict confidentiality requirements.

Our website and electronic newsletters may contain links to other websites operated by third parties. We are not responsible for the privacy practices of these third parties. Should you follow links to websites operated by other businesses, we recommend that you take the time to review their privacy policy (if such policy exists).

Although we treat our privacy and security obligations with the utmost care, we cannot guarantee the security of your personal information.

The collection and storage of personal information is strictly limited to circumstances where it is needed for our compliance with the APPs, the Act, the Rules or an explicit purpose which we outline to you. If we collect your personal information, we collect that information provided that it is reasonable for us to do so in the circumstances and allowed/required by law. We generally collect personal information to:

• Verify your identity – to meet our mandatory obligations under the Act and Rules (which may include ARNECC requirements and KYC policies);
• Provide legal services – to open files under a client’s name, provide legal advice, represent you in transactions or matters generally, and manage your files;
• Conflict check – to ensure that our professional obligations are not conflicted with other clients and/or matters before representing a new client;
• Move/access funds with authority – where it is required by the Act, to verify the origin of funds involved in specific transactions; and
• Administrative/billing – to manage our trust account, process payments from our trust account or general account, issue invoices on our matters, or recover debts owing.

We will only disclose or use your personal information for the primary purpose for which it was collected, for a related secondary purpose you would reasonably expect, or as required by law. The primary purpose is to provide you with legal representation and the advice, transaction or other services incidental to that representation. Your personal information may be disclosed to external auditors, government bodies, barristers, valuers, third party service providers engaged on your behalf, courts, opposing parties in the event proceedings are on foot, law enforcement, authorities such as AUSTRAC, recipients where required by the Act or recipients as a result of court orders.

There may be circumstances where we disclose your personal information to an overseas recipient, in the course of providing our services or managing business operations. In circumstances where an overseas recipient (contractor) exists outside Australia, we will enter into an enforceable contractual agreement with the overseas recipient, prior to them being disclosed your personal information. An agreement with an overseas recipient will include a requirement of confidentiality in handling personal information in accordance with the APPs, the Act, the Rules, and this policy.

In most circumstances, we hold your personal information for a period of seven (7) years. Depending on the type of information and its purpose, this information may be held indefinitely. We do not sell, rent, trade or share personal information to third parties for a commercial and/or marketing purpose.

We will provide access to the personal information we hold about you unless an exception at law applies. You may request access to this personal information at any time, pending our verification of your identity. We may need to contact other entities to properly respond to your request, and as such, will endeavour to provide access to your personal information within a reasonable timeframe.

If your request is vexatious, unlawful, or you are not the authorised person to whom the information relates, we may not provide you with access to your personal information. If we deny access to your personal information, we will provide you with a reason unless an exception at law applies (for example if we are restricted from doing so with respect to the Act and/or Rules).

You have the right to access the personal information we hold about you. You may also request that your personal information be corrected if it is inaccurate, out of date, expired or incomplete. Our personal information about you may otherwise be updated by way of our continued due diligence obligations under the Act and Rules. If you request that your information be updated, we will respond within a reasonable time frame. We may need to contact other entities to properly respond to your request, which may delay our response to you in confirming or discussing a change of personal information with you.

If you have a privacy complaint about how we have dealt with your personal information or our compliance with the APPs, please contact us at:

Email

complaints@thompsonlegal.com.au

Phone

(07) 5239 8600

Address

PO Box 321, Bli Bli QLD 4560

We will respond to your complaint within a reasonable time. If you are dissatisfied with our response to your complaint, you are entitled to make a complaint to the Office of the Australian Information Commissioner at:

Email

enquiries@oaic.gov.au

Phone

1300 363 992

Website

https://www.oaic.gov.au/

Information surrounding the APPs can be found at the website of the Office of the Australian Information Commissioner here: https://www.oaic.gov.au/privacy/australian-privacy-principles

Email

info@thompsonlegal.com.au

Phone

(07) 5239 8600

Address

101/310 David Low Way, Bli Bli Queensland 4560
PO Box 321, Bli Bli QLD 4560