Your privacy is important to us. We are committed to managing personal information you may provide to us in responsible way and in accordance with the Privacy Act 1988, the Australian Privacy Principles and any other legal obligations.
This privacy notice sets out how Global Loan Agency Services Australia Pty Ltd, Global Loan Agency Services Australia Nominees Pty Ltd and Global Loan Agency Services Australia Specialist Activities Pty Ltd (GLAS Australia and members of the GLAS Group), also referred to in this privacy notice as “we”, “our” or “us”, collect and use your personal information.
We are committed to being open, transparent and protecting your information; therefore, this notice includes information about how we store and protect your information, who we share your information with and how long we hold your information for. This notice also outlines your rights and the actions you should take if you are concerned with the way GLAS Australia is handling your personal information. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this privacy notice.
All members of GLAS Australia are APP entities under the Privacy Act 1988 and are committed to comply with the Australian Privacy Principles. Our Privacy Officer is responsible for ensuring GLAS Australia and its employees comply with the Australian Privacy Principles and is the first point of contact for individuals whose information is held can be contacted at email@example.com.
References in this notice to “your information” are to personal information that you provide or that is provided to us.
Information held by GLAS Group entities in our international locations is held strictly in accordance with the applicable legislation and legal obligations in each of those jurisdictions.
Why we collect your personal information
GLAS Australia may collect, hold, use or disclose your personal information in order to:
- Verify your identity (as we are required to do under Anti‐Money Laundering and Counter Terrorism Financing legislation).
- Provide you with our services.
- Respond to queries, complaints or to provide customer service.
The type of product or service we are providing to you may determine what information we will collect about you.
How we collect your personal information:
- From you directly.
- From external sources, such as:
- A legal representative
- A financial adviser/broker
- An authorised representative, or others who are part of providing your services
- Information verification service providers.
What type of personal information may be collected by GLAS Australia?
Under Anti‐Money Laundering and Counter Terrorism Financing legislation, GLAS Australia is required to ‘know its customers’ (KYC). This requires GLAS Australia to collect personal information from which your identity is apparent or from which your identity can be reasonably ascertained. This may include:
- Full name (may include marital status)
- Photographic Identification
- Personal business email address
- Telephone Number
- Date of birth
- Passport number
- Address and Proof of address
- Bank account details such as sort code/BSB and account number
- Name/s of the executor
- Name/s of the beneficiary
- Details about authorised signatories in connection with facilities managed by us
- Copies of any relevant trust deeds, partnership agreements or constitutions, which may be relevant to comply with Anti‐Money Laundering and Counter-Terrorism Financing legislation.
We may also collect personal information about individuals who are business contacts of GLAS Australia.
As part of our recruitment process for employees/contractors we may collect and store personal information about you, including your name, contact details, date of birth, citizenship, employment references, criminal records, bankruptcy records, education and employment history. If you are employed by GLAS Australia we may also hold your tax file number, financial information and bank account details.
How we use your personal information
Generally, we will use and disclose information provided by you for the purpose for which it was collected (or for related purposes which could reasonably be expected) or as otherwise required under an Australian law or a court/tribunal order.
We may use and disclose information provided by you in the following ways:
- To contact you in relation to a transaction/agreement.
- To verify the identity of a customer or potential customers in line with our KYC procedures and the legal requirement to fulfil our obligations under Anti-Money Laundering and Counter Terrorism legislation.
- To prevent fraud or illegal activity.
- To make payments as agent or trustee.
- To deal with any enquiries or complaints.
- For communication purposes including to contact you to offer our services for business purposes, for surveys or questionnaires, or to provide information about our products and services. We respect your rights to ask us not to do this.
- For any additional purpose, where you have provided your consent.
Who we share your personal information with
If the personal information you provide to our transaction managers is for KYC purposes, then your personal information will be securely emailed to our Compliance Team in the UK to process and securely store.
When your name and personal business email address are shared with us in order to send you marketing communications, your name and personal business email address will be shared with our third-‐party marketing platform, MailChimp. The same information will also be shared with our third-‐party Customer Relationship Management system (CRM).
Your personal information may be disclosed when we believe in good faith that the disclosure is:
- required by law;
- to protect the safety of our employees, the public or GLAS Group property;
- required to comply with a judicial proceeding, court order or legal process; or
- for the prevention or detection of crime (including fraud, money laundering or terrorism financing); and/or
- with your consent
Storage, Security and Transfer of Personal Information
GLAS Australia takes the security and protection of your personal information very seriously. We have technical and organisational security measures to ensure that your personal information is secure against both external and internal threats and access to personal information is restricted to those who need to process it. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. GLAS Australia has also established backup and recovery procedures in the unlikely event that your personal information is lost or accidentally destroyed.
Once your personal information has been processed, it will be securely stored in a private portal on Microsoft Office 365 which has restricted access.
Your name and personal business email address will be stored on our third‐party CRM system which has access restricted to only those who have a business need to see this information. Our CRM is SOC 2 compliant and maintains reasonable security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. Our CRM complies with the Australian Privacy Principles.
MailChimp’s servers are located in the United States so information may be transferred to, stored, or processed in the United States. However, MailChimp participates in and has certified its compliance with standards which comply with the Australian Privacy Principles.
GLAS Australia may transfer your personal information outside Australia. If this happens, we will make sure that suitable safeguards are in place and that your personal information is protected at the same level that it is in Australia.