Member Check Pty Limited ACN 129 012 344 (‘MemberCheck’, ‘we’ , ‘us’ or ‘our’) is the owner and operator of the MemberCheck service, an Anti Money Laundering and Counter Terrorism Financing (AML/CTF) service designed for entities required to comply with AML/CTF obligations and regulations.
MemberCheck is committed to protecting the privacy of individuals whose information is collected, including information contained in our databases, and to assisting in resolving any issues that may arise in relation to this information. This policy describes how MemberCheck handles personal information collected.
MemberCheck is dedicated to being transparent about what personal information we collect and how we use it. MemberCheck may review and update this policy from time to time to take account of new laws, technology, changes to our operations, and the changing business environment. Updates will be published on the MemberCheck website.
We collect personal information from:
The databases maintained by MemberCheck contain personal information about individuals. MemberCheck obtains personal information for its databases from a commercial supplier of AML/CTF watchlists and from MemberCheck’s clients regarding their members and customers. This information may typically include an individual’s name, date of birth, residential address, a client number allocated to the individual and gender. The information received from our commercial supplier of AML/CTF watchlists may also include information about criminal records, personal relationships and other publicly available information. MemberCheck seeks assurances from all its data sources that the information has been collected and is held in accordance with applicable privacy laws. Because of the nature of the MemberCheck service, it is not possible to collect this information directly from the individual.
MemberCheck will not use this personal information for any purpose other than to assist its clients in meeting their obligations under their AML/CTF legislation. MemberCheck maintains strict security over this personal information.
MemberCheck also collects personal information from clients permitted to use the MemberCheck service when the client registers with the service and a client contact logs in for the first time. This information may include the client contacts’ name and contact details. Where there are several users in a client’s organisation, those users’ names and contact details will also be collected and may be provided by another user in the client organisation. If this information is not provided, you cannot use the MemberCheck service. This information is used only to track users of the MemberCheck service.
If we hold your personal information through Watchlists or clients, this is not controlled by us and you should refer to their respective privacy policies.
MemberCheck databases are held and stored by MemberCheck or a cloud services provider.
We will use your personal information:
MemberCheck will share personal information collected for our databases with its clients and users of the MemberCheck service or as required by law, and only for the above (or related) purposes. MemberCheck may also disclose the information to its related entities for purposes associated with running the MemberCheck service or other usual business activities.
Personal information from watchlists held in our databases may be disclosed to overseas recipients as part of the MemberCheck service. The recipients could be located in any country, and it is not practicable to specify those countries in this policy.
Personal information collected from clients who use the MemberCheck service is retained only for the duration of the client’s subscription and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we will make sure it is deleted or anonymised.
If you are a registered user of the MemberCheck service, you have various rights in relation to your personal information, and we respect those rights. With regards to marketing emails, you can request us not to send you these at any time – just follow the ‘update your preferences’ or ‘unsubscribe’ from this list’ options at the end of the email. You may still receive important account and service related information email notifications.
You also have rights to:
We may collect personal information for our other business activities such as interactions with suppliers, responding to general business enquiries, recruitment activities, resolving complaints or for security purposes. This information is generally only contact information (name, address, email and telephone numbers) collected directly from you or someone you have permitted to provide the information to us. When you use a mobile device to interact with MemberCheck, you authorise your mobile carrier to disclose your mobile account details for the purpose of verifying your identity. Those details may include your name, address, and device details.
If the information is provided for recruitment purposes, we might collect more detailed information about you that is relevant for assessing your suitability for a position with us, such as any personal information contained in your resume, including your employment history. Whenever you provide referee details, you must have the referee’s consent to do so. Referee details will only be used for reference checking. In the event that you do not provide the information required, we may not be able to respond or interact with you or, in the case of recruitment, to consider your application.
Also, if you use our website, we will record your contact details, which may include your name, email address, address and phone number if you send them to us in an email or complete an online contact or demo request form. We will use your personal information to deal with your specific enquiry. If you do not provide this information, we may not be able to respond to your enquiry.
Personal information collected for these other business activities will only be disclosed to our related entities and our and their personnel, our contractors, suppliers, service providers, business partners, recruiters, referees, or others as you would reasonably expect for the above (or related) purposes and only otherwise disclosed as required by law.
The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements). We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it is deleted or anonymised.
You have various rights in relation to your personal information, and we respect those rights. With regards to marketing emails, you can request us not to send you these at any time – just follow the ‘update your preferences’ or ‘unsubscribe’ from this list’ options at the end of the marketing email.
You also have rights to:
If you communicate with us through a social networking service such as Twitter or Linked In, the social network provider and its partners may collect and hold your personal information overseas. This is not controlled by us and you should review their privacy policies.
This information is however anonymous.
MemberCheck will track the pages you visit via Google Analytics. This information is disclosed to Google Analytics when you visit our site and may be stored overseas in multiple countries.
We take reasonable steps to protect all information which we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. However, as the transmission of data over the internet is not totally secure, we cannot guarantee the security of your data during transmission.
All personal information held electronically is kept on secure servers and protected by firewall security systems. As noted above, we may use a third party cloud service provider to store our information. We may also hold some personal information in hard copy. This may include client files, invoices and business cards. This information is subject to restricted access.
If you wish to access the personal information we hold about you or you think that your personal information is inaccurate and needs correction, please contact us at the address below. We will take reasonable steps to keep your personal information accurate, complete and up-to-date.
If you have a complaint concerning your privacy, please contact us in writing using the details below. Any complaint will be investigated by our Privacy Officer and responded to in a reasonable time.
All privacy-related enquiries or complaints should be directed to:
The Privacy Officer
MemberCheck Pty Ltd
PO Box 160
Phone: +612 9453 5466