PRIVACY POLICY

Purpose

This policy outlines our approach to maintaining accurate and secure records in compliance with ASIC RG 205 and other relevant Australian regulatory requirements. Proper record-keeping is essential for legal compliance, risk management, and ensuring transparency in our business operations.

Record Retention

We retain various records for different durations based on legal and regulatory obligations:

Loan applications and supporting documents: Retained for at least 7 years after loan settlement.
Compliance reports and audit records: Maintained as required by ASIC and other regulatory bodies.
Customer communications related to financial transactions: Stored for at least 7 years for reference and compliance purposes.
AML/CTF records: Customer identification and transaction reports are stored for a minimum of 7 years.

All records are maintained in both electronic and physical formats where applicable.

Security Measures

We employ stringent security measures to safeguard records from unauthorized access, loss, alteration, or destruction. These measures include:

Data Encryption: Sensitive records are encrypted both in transit and at rest.
Access Controls: Only authorized personnel have access to critical records, based on their job responsibilities.
Regular Backups: Digital records are backed up periodically to ensure data integrity and disaster recovery preparedness.
Physical Security: Paper records are stored in secure, access-controlled locations.

Compliance Monitoring & Audits

We conduct regular internal audits to verify that records are maintained in accordance with legal and regulatory requirements. Any discrepancies or gaps identified during audits are promptly addressed through corrective action plans.

Disposal of Records

Records that have surpassed their retention period are securely disposed of using industry best practices. This includes:

Shredding of physical documents to prevent unauthorized access.
Secure deletion of digital records using data-wiping techniques.

Continuous Improvement

We regularly review and update our record-keeping policies to align with evolving regulatory requirements and industry best practices. Staff training on record management is conducted periodically to ensure compliance.

anti money laundering & counter terrorism financing policy

Purpose

This policy ensures compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). It outlines our commitment to detecting, preventing, and reporting money laundering and terrorism financing activities.

Customer Identification

We implement a robust Know Your Customer (KYC) process, which includes:

Collecting valid identification documents (e.g., driver’s license, passport, Medicare card).
Verifying client identities using government and third-party databases.
Conducting enhanced due diligence for high-risk clients.

Transaction Monitoring

We actively monitor financial transactions to identify suspicious activities, including:

Large cash transactions exceeding regulatory thresholds.
Unusual transaction patterns, such as rapid movements of funds.
Transactions involving high-risk jurisdictions or entities with known financial crime associations.

Reporting Obligations

We comply with all reporting requirements under the AML/CTF Act, including:

Suspicious Matter Reports (SMRs): Filed with AUSTRAC when we detect potentially suspicious activities.
Threshold Transaction Reports (TTRs): Submitted when transactions exceed $10,000 in cash.
International Funds Transfer Instructions (IFTIs): Reported when funds are sent or received from overseas accounts.

Staff Training & Compliance

All staff members receive regular AML/CTF training to ensure awareness of regulatory obligations and risk indicators. Our compliance team conducts periodic audits and updates policies to align with evolving regulatory standards.

Record Keeping

We retain all AML/CTF-related records, including transaction data and customer identification documents, for at least seven (7) years as required by law.

Internal Controls and Risk Assessment

We maintain a risk-based approach to compliance by conducting regular risk assessments of clients and transactions. Implementing strong internal controls to mitigate financial crime risks, reviewing and updating AML/CTF policies to reflect changes in legislation and emerging threats.