We are subject to the Privacy Act 1988 (Cth) (“Privacy Act”), and as such, are committed to protecting the privacy of our contacts, customers, suppliers, and employees by complying with the Australian Privacy Principles (“APPs”) found in Schedule 1 of the Privacy Act.

This is the Privacy Policy of Milne Legal (ABN 99 860 705 195).

1. The kinds of personal information we collect

1. Contact details such as name, role or position, address, email address, relevant phone numbers, and a verification document for some of this (e.g. passport or driver’s licence);
2. Information relating to your circumstances and affairs relevant to the matter or matters in which we are instructed;
3. Information about your legal interests and requirements and the legal services that you may wish for us to perform;
4. Information regarding our communications with you to ensure we keep track of all conversations; and
5. If you are an employee or prospective employee, information about your qualifications, skills, work experience, and background.

2. How we collect personal information

2.1 We collect personal information by various means, including when:

1. You contact us with a question or inquiry;
2. You instruct us to act for you and we onboard you as a new client to add you to our system, including InfoTrack;
3. Other clients provide information relating to you or your party where relevant to the advice or services we are providing; or
4. We undertake a search or investigation.

2.2 Where practicable, we collect personal information about you directly from you. However, we may have collected information about you from a third party, such as a client, a third-party information provider, the Courts, or a person responding to our questions or inquiries.

2.3 We are required to collect identity information, beneficial ownership details for trusts, transactional data, and verification documents from our clients as required under the Legal Profession Act 2007 (Qld). Furthermore, we are required to collect accurate names and contact details to comply with trust account record-keeping obligations under the Legal Profession Regulation 2017 (Qld) and to ensure we meet our professional obligations, including our duties to the Court.

2.4 If you are a client and do not provide us with your name and address information, we cannot act for you.

2.5 If you do not provide us with accurate personal information, we may not be able to carry out your instructions or achieve the purpose for which the information has been sought.

3. The purposes for which we collect, hold, use and disclose personal information

3.1 We collect, hold and use personal information in order to:

1. Respond to your enquiries;
2. Provide legal services;
3. Employ competent and diligent personnel;
4. Monitor or improve the use of and satisfaction with our legal services;
5. Let you know about legal developments, our expertise, and legal services that may be of interest to you; and
6. Comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

3.2 We disclose personal information:

1. In order to carry out the instructions of our clients;
2. Subject to our confidentiality obligations, when using services in support of our legal practice; or
3. If we believe you may be involved in suspicious activity.

3.3 The above sections are relevant to our obligations as a Tranche 2 entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and ensure we comply by documenting and verifying the relevant personal information.

4. The parties to whom your personal information is disclosed

4.1 Subject to our confidentiality obligations, we may share relevant personal information with:

1. Parties related to a matter you have with us, government authorities, and service providers, as reasonably required to carry out your instructions; and
2. Third-party service providers, such as InfoTrack, who assist us with archival, auditing, accounting, legal, business consulting, website, or technology services. This may include identity-verification providers and electronic-verification services used to confirm your identity.

4.2 We may also disclose personal information to regulatory authorities, including AUSTRAC, where required by law.

4.3 We will also disclose your information if required by law or in circumstances permitted by the Privacy Act—for example, where we have reasonable grounds to suspect that unlawful activity, or misconduct of a serious nature relating to our functions or activities, has been, is being, or may be engaged in in connection with any aspect of our work.

5. Disclosure of information outside the jurisdiction of collection

5.1 We do not disclose personal information to overseas recipients.

7. Security

7.1 We take reasonable physical, technical, and administrative safeguards to protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. For example, we maintain our files in secure offices, limit access to personal information, and store all private information on a secure site.

8. Access, correction and updating of personal information

8.1 You can contact us to access, correct, or update your personal information. Unless we are subject to a confidentiality obligation or another restriction on giving access to the information, and we are permitted to refuse access under the Privacy Act, we will endeavour to make your information available to you within 30 days. Examples of circumstances where we may refuse to give you access to your personal information include where:

1. Giving access would be unlawful;
2. We reasonably believe that giving you access would pose a serious threat to the life, health, or safety of any individual or to public health or public safety;
3. Giving access would have an unreasonable impact on the privacy of others;
4. The information could reveal the intentions of a party in negotiations;
5. Giving access could prejudice the taking of appropriate action in relation to unlawful activity; or
6. Giving access could reveal evaluative information in a commercially sensitive decision-making process.

8.2 If you request that we correct your personal information, we will correct it or, if we consider it more appropriate, note your request for amendment on your record.

8.3 We will not charge you to make a request to access your record, but we may charge you to provide access depending on the costs associated with obtaining and providing the material.

8.4 These actions can usually be taken by contacting a customer relations representative using the contact information in the “Contact Us” section below.

9. Notification of changes

9.1 If we decide to change our Privacy Policy, we will send you a copy of our revised policy or post a copy on our website.

10. Complaints and contact details

10.1 If a breach of this Privacy Policy occurs, a complaint may be made to us by:

1. Emailing admin@milnelegal.com.au;
2. Calling us on 07 3210 0943; or
3. Sending correspondence to:
   GPO Box 107
   Brisbane QLD 4001
   Attention: Robert Milne, Privacy Officer

We will endeavour to respond to any complaint within 30 days. If you are not satisfied with our response, you may seek a review by contacting the Office of the Australian Information Commissioner using the information available at www.oaic.gov.au/privacy/privacy-complaints.

Liability limited by a scheme approved under professional standards legislation.