Privacy Policy

1. Introduction

Sutton Anderson ("Sutton Anderson", "we", "us" or "our") is committed to protecting your personal information and handling it in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information, including information used to verify your identity.

Sutton Anderson Pty Ltd is committed to supporting the 'National Privacy Principles' issued pursuant to the Federal Privacy Act, 1988.

Sutton Anderson Pty Ltd is one of the leading property services firm in Australia. Our people are committed to providing innovative solutions for our clients across a broad range of services and locations. In order for us to continue provide such solutions, we collect and use personal information.

2. What Personal Information We Collect

We may collect the following personal information about you:

Full name
Date and place of birth
Residential or business address
Email address and phone number
Government-issued identification details, such as driver licence, passport, Medicare card or other ID document numbers
Biometric information, such as a facial image or short video used to verify your identity
Information about the services we provide to you and any related transactions
Any other information you choose to provide to us

We only collect personal information that is reasonably necessary to carry out our business activities.

2B. What Personal Information We Collect

We generally collect personal information directly from you when you:

Contact us or make an enquiry
Use our website
Complete forms or provide documents to us
Use our services or interact with us
Complete an identity verification process

We may also collect personal information from:

Identity verification providers and official record holders
Publicly available sources
Professional advisers and representatives acting on your behalf
Third parties where permitted or required by law

Some information may also be collected automatically through our website and online systems, including through cookies and analytics tools.

3. Why We Collect Your Personal Information

We collect, use and disclose your personal information to:

Verify your identity
Provide and manage our services to you
Communicate with you about your account with us
Meet our legal and regulatory obligations, including anti-money laundering and counter-terrorism financing (AML/CTF) requirements
Detect and prevent fraud, and keep our systems secure
Improve our services

4. Identity Verification and Government Data Matching (DVS)

To verify your identity, we may use electronic identity verification services, including the Australian Government's Document Verification Service (DVS).

Where you have consented, your name, date of birth and identity document details will be securely sent to the relevant Commonwealth or State authority that issued your document. This may include passport offices, driver licence authorities, the Department of Home Affairs, Births Deaths and Marriages, or other authorised record holders.

These authorities check whether the details you have provided match the records they hold.

We do not receive a copy of your government records. The authority returns a match result only, confirming whether your details match (yes or no).

This process may be carried out through accredited identity verification providers, including APLYiD (APLYiD Pty Ltd, ABN 36 632 866 794) and its sub-providers.

More information about the DVS is available at idmatch.gov.au.

5. Biometric Information

As part of identity verification, we may collect biometric information, such as a facial image or a short video of you holding your ID.

Biometric information may be used to:

Confirm that you are a real person and physically present
Match your image to the photograph on your identification document
Reduce the risk of fraud and identity theft

Biometric information is treated as sensitive information under the Privacy Act. We only use it for identity verification and related compliance purposes, and only with your consent.

6. Consent to Collection and Identity Verification

By providing your personal information and completing the identity verification process, you consent to:

The collection, use and disclosure of your personal information for identity verification, AML/CTF and related compliance purposes
The collection and use of biometric information, such as a facial image or video, for identity verification
Your information being checked against records held by Commonwealth and State authorities through the DVS
Your information being shared with our authorised identity verification providers, including APLYiD

Your consent is voluntary. You can withdraw your consent at any time by contacting us using the details in section 13.

If you do not consent, or do not provide the information we need, we may not be able to verify your identity electronically. In that case, we may need to verify your identity in another way, or we may not be able to provide our services to you.

7. Disclosure of Personal Information

We may disclose your personal information to:

Identity verification providers, including APLYiD and its authorised sub-providers
Commonwealth and State authorities and official record holders, through the DVS
Our employees and authorised representatives, on a need-to-know basis
Our professional advisers, such as lawyers, accountants and auditors
Trusted technology and service providers that help us operate our business
Regulators, law enforcement or other third parties where required or authorised by law

We do not sell your personal information.

8. Overseas Disclosure

Some of our service providers may store or process personal information outside Australia.

Where this happens, we take reasonable steps to ensure that your personal information is handled in line with the Australian Privacy Principles, including through contractual protections with our providers.

8B. Website Use, Cookies and Analytics

When you use our website, we may collect certain information automatically, including:

Your IP address
Browser type and device information
Pages visited and time spent on our website
Referral sources and website interaction information

We may use cookies, analytics tools and similar technologies to improve website functionality, analyse website traffic, enhance security and improve our services.

You can usually modify your browser settings to disable cookies, although this may affect the functionality of our website.

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those external websites.

9. Data Security and Storage

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification or disclosure.

These steps include secure systems, access controls, and encryption in transit and at rest where appropriate.

We retain personal information only for as long as we need it for the purposes set out in this Policy, or as required by law. When we no longer need your information, we securely delete or de-identify it.

Where biometric information is collected for identity verification purposes, we take additional steps to protect that information due to its sensitive nature. Where permitted by law and practicable, biometric information will be securely deleted or de-identified once identity verification and related compliance processes have been completed.

10. Access and Correction

You have the right to ask for access to the personal information we hold about you, and to ask us to correct it if it is inaccurate, incomplete or out of date.

To make a request, please contact us using the details in section 13. We will respond within a reasonable time.

Before providing access to personal information or making corrections, we may require you to verify your identity.

11. Direct Marketing

From time to time, we may use your contact details to send you information about our services that we think may be of interest to you.

You can opt out of marketing communications at any time by using the unsubscribe link in our messages, or by contacting us using the details in section 13.

12. Privacy Complaints

If you have a complaint about how we have handled your personal information, please contact us first using the details in section 13.

We will acknowledge your complaint, investigate it, and respond to you within a reasonable time.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

13. Contact Details

If you have any questions about this Policy, or want to exercise any of your privacy rights, please contact us:

Email:
info@suttonanderson.com.au

Phone:
(02) 9438 1600

Address:
C2/202-210
Willoughby Road,
Crows Nest, NSW 2065

14. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in the law.

The latest version will always be available on our website. Where changes are significant, we will take reasonable steps to notify you.