Our fine print

Acknowledgement of Country

We acknowledge the traditional custodians of Australia and acknowledge their continuing connection to land, sea and community. We pay our respects to the people, the cultures and the elders past and present.

Privacy

How we collect personal information

1. About this policy

Jamili & Associates (ABN 20 679 841 831) is a registered conveyancing practice based in Adelaide, South Australia. In this policy, “we”, “us” and “our” mean Jamili & Associates.

This policy explains what personal information we collect, why we collect it, who we share it with, how we protect it, how long we keep it, and how you can access it or make a complaint.

Our practice involves handling information that is unusually sensitive: identity documents, dates of birth, financial details and title records. We treat that seriously, and this policy is written to be read rather than filed away.

2. How the Privacy Act applies to us

From 1 July 2026, conveyancers became reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act). Because we are a reporting entity, the Privacy Act 1988 (Cth) (the Privacy Act) applies to us and we are bound by the Australian Privacy Principles (APPs) in relation to personal information we handle for the purposes of, or in connection with, our AML/CTF obligations. This applies regardless of our size or turnover.

As a matter of firm policy, we apply the standards in this document across the whole of our practice, not only to the parts the Privacy Act strictly reaches. We think that is the right way to run a conveyancing file, and it avoids the artificial exercise of separating identity information from the rest of your matter.

3. What personal information we collect

The information we collect depends on your role in a transaction and the service we are providing. It generally includes the following.

3.1 Identity and contact information

•     Full name, any former or other names, and date of birth

•     Residential and postal addresses, email address and telephone numbers

•     Details taken from identity documents, including document type, number, expiry date and issuing authority

•     Photographs of identity documents and a photograph or short video of your face, where verification is carried out electronically

3.2 Transaction and financial information

•     Details of the property, including title reference, address and plan details

•     Contract, price, deposit and settlement details

•     Bank account and payment details for settlement and disbursement of funds

•     Loan, mortgage and discharge details, and the identity of your lender or broker

•     Information about the source of funds and source of wealth used in the transaction

3.3 Anti-money laundering information

To meet our obligations under the AML/CTF Act and the AML/CTF Rules, we collect and generate information about you and, where relevant, about persons connected to you. This includes:

•     Beneficial ownership details for companies, trusts and other non-individual clients

•     Whether you are a politically exposed person, and the results of sanctions and adverse media screening

•     Our assessment of the money laundering and terrorism financing risk associated with providing our services to you

•     Records of the verification steps we took and their outcome

3.4 Sensitive information

Some of what we collect is sensitive information under the Privacy Act, which attracts a higher level of protection. In our practice this may include:

•     Biometric information. Where identity verification is carried out electronically, a facial image may be compared against the photograph on your identity document. Biometric information used for verification is sensitive information.

•     Membership of a political association. This may be collected where it is relevant to determining whether you are a politically exposed person.

•     Criminal record information. This may arise through sanctions and adverse media screening.

We collect sensitive information with your consent, or where the collection is required or authorised by Australian law, including the AML/CTF Act and the AML/CTF Rules. We will seek your consent before biometric verification is used, and we will offer you an alternative means of verifying your identity if you prefer not to use it.

3.5 Website information

Our website collects limited technical information such as IP address, browser type and pages visited.

4. How we collect personal information

Wherever it is reasonable and practicable, we collect personal information directly from you: in person, by telephone, by email, or through an online form or verification link we send you.

We also collect personal information from other sources, including:

•     Your agent or representative, such as a real estate agent, broker, accountant, lawyer or attorney under a power of attorney

•     The other party to the transaction and their conveyancer or solicitor

•     Your lender or their settlement agent

•     Public registers and government sources, including Land Services SA, the Australian Securities and Investments Commission, PlanSA, local councils, SA Water and RevenueSA

•     Identity verification, sanctions screening and adverse media services engaged by us

There are limited circumstances in which the AML/CTF Act prevents us from telling you that we have collected or reported information about you. Where that applies, we will not be able to notify you.

5. Why we collect and use personal information

We use personal information for the purpose for which it was collected, and for related purposes you would reasonably expect. Our main purposes are:

•     Providing conveyancing and related services to you, including preparing, reviewing and lodging documents and attending to settlement

•     Verifying your identity, both to meet our obligations under the AML/CTF Act and to meet the verification of identity standard required for land transactions in South Australia

•     Carrying out customer due diligence, ongoing due diligence and transaction monitoring under the AML/CTF Act

•     Reporting to AUSTRAC where we are required to do so

•     Conducting searches and enquiries necessary for the transaction

•     Managing our relationship with you, including invoicing, trust accounting and responding to your enquiries

•     Meeting our professional, regulatory, record keeping and insurance obligations

6. Who we disclose personal information to

We disclose personal information only where it is necessary for the purposes described above, or where we are required or authorised to do so by law. We do not sell, rent or licence your personal information.

The recipients typically include:

Recipient	Purpose
AUSTRAC	Suspicious matter reports, threshold transaction reports and other reporting required under the AML/CTF Act
Land Services SA	Title searches, registration and lodgement of dealings
PEXA	Electronic settlement of land transactions
The other party and their representative	Conducting and completing the transaction
Lenders, brokers and their settlement agents	Arranging discharge, registration of a mortgage and settlement of funds
Local councils, SA Water and RevenueSA	Rates, taxes and statutory certificates
Our banks and trust account providers	Receiving and disbursing settlement funds
Courts, regulators and government agencies	Where required or authorised by law
Our professional advisers and insurers	Obtaining advice and managing claims

 

We also disclose personal information to service providers who support our practice, including our practice management system, document signing platform, identity verification provider, information technology and cloud hosting providers, and archiving and secure destruction providers. We require those providers to handle personal information consistently with this policy and with the Privacy Act.

7. Sending personal information overseas

Some of the service providers we use store or process personal information outside Australia. We remain accountable for how those providers handle your information, and we take steps that are reasonable in the circumstances to ensure they handle it consistently with the APPs, including through our contractual arrangements with them.

We use Sumsub (Sum and Substance Ltd) to verify identity. Sumsub states in its own privacy notice that personal information, including biometric information, is stored on its servers in the European Union, unless a local data residency requirement applies.

Our practice management, email and document signing platforms may also store data outside Australia. 

If you would prefer that your identity be verified without your information being sent overseas, please tell us before verification begins and we will discuss the alternatives available to you.

8. How we protect personal information

We hold personal information in electronic systems and, to a limited extent, in physical files. We take reasonable steps to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure. Those steps include:

•     Multi-factor authentication on all firm accounts

•     Encryption of data in transit and at rest

•     Restricting access to personal information to those in the firm who need it

•     Confidentiality obligations on our staff and contractors, and regular training

•     Assessing the security practices of our service providers before we engage them, and imposing contractual obligations on how they handle personal information

•     Secure destruction of physical records and deletion of electronic records at the end of their retention period

•     A documented data breach response plan

No system is completely secure. If a data breach occurs that is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme, except where notifying you would be inconsistent with a secrecy provision in the AML/CTF Act.

9. How long we keep personal information

We keep records for as long as we need them, and no longer, subject to the retention periods the law imposes on us.

The AML/CTF Act requires us to keep certain customer due diligence records for seven years after the end of our business relationship with you, or seven years after the date of an occasional transaction.

Importantly, the AML/CTF Act does not require us to retain scanned copies or photocopies of your identity documents themselves. What we are required to keep is the information taken from those documents, the type of document, what we did to verify your identity, and the outcome. Our practice is therefore to record the details we need and to take reasonable steps to destroy or de-identify full copies of driver licences, passports and similar documents once they are no longer needed.

Where we hold personal information that we no longer need for any purpose permitted under the Privacy Act, and we are not required by law to retain it, we take reasonable steps to destroy or de-identify it.

10. Accessing and correcting your information

You may ask us for a copy of the personal information we hold about you. Please make the request in writing to our Privacy Officer. We will need to confirm your identity before we respond. We aim to respond within 30 days.

There are limited grounds on which we may refuse access, including where giving access would be unlawful or would breach the tipping off provisions of the AML/CTF Act. If we refuse, we will give you written reasons and tell you how to complain, unless giving reasons would itself be inconsistent with our legal obligations.

We may charge a reasonable fee for the cost of locating, retrieving and copying the information. We will tell you the amount before we incur it. We do not charge for making a request.

If you believe information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please tell us and we will take reasonable steps to correct it.

11. Dealing with us anonymously

You may make a general enquiry of us anonymously or under a pseudonym. However, we cannot act for you in a conveyancing matter without verifying your identity. Both the AML/CTF Act and the verification of identity requirements that apply to land transactions in South Australia require us to know who you are, so anonymity is not available once we are engaged.

12. Automated decision making

From 10 December 2026, the Privacy Act will require privacy policies to disclose where a computer program uses personal information to make, or substantially assist in making, a decision that could reasonably be expected to significantly affect a person’s rights or interests.

13. Complaints

If you are concerned about how we have handled your personal information, please contact our Privacy Officer in writing in the first instance. Please set out your concern clearly so that we can investigate it properly. We will acknowledge your complaint promptly and aim to respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001

Telephone: 1300 363 992

Website: www.oaic.gov.au

14. How to contact us

Jamili & Associates

Level 30, 91 King William Street, Adelaide SA 5000

Email: m[at]jamili.com.au

Telephone: Zero Eight Seven Two Zero Zero Zero Zero Seven Five

15. Changes to this policy

We review this policy periodically and may update it. The current version is always available on our website and on request. Where we make a material change, we will note it on our website.

Disclaimer

While we will try and exercise due care in ensuring the accuracy of the material contained on our website, the information provided is made available on the mutual understanding that we are not rendering professional advice on here. Our website may also not cover all the information available on a particular matter. 

Before relying on any material contained on our website, we urge that you obtain appropriate professional advice relevant to your particular circumstances so that you can independetly evaluate the material’s accuracy, currency, completeness and relevance for your personal circumstances/purposes.

From time to time, we may provide links to other websites. This is done for your convenience and does not constitute endorsement from us. We accept no responsibility for material contained in any website that is linked to this site.

Further notices

1. Your use of the information and data contained in our website is at your sole risk.
2. You should never seek to rely on the information within our site.
3. Any information displayed within our website is provided for educational and informational purposes only and does not constitute professional and/or legal advice.
4. You may use automatic language translations services at your own risk.
5. Material provided for free of charge may be read, viewed, listened to or downloaded for your convenience and information. However, while we may make every effort to ensure that the material is complete, current and free from error and virus contamination, we do not guarantee, promise or claim that to be the case. 
6. The information and/or data on our website is subject to change without notice. 

We (including our officers and employees):

• do not make a representation (express or implied), that the information and data contained on our website is accurate.
• accept no liability however arising from any loss resulting from the use of our website and any information and data or reliance placed on it (including any translated information and data)
• do not make any representations (express or implied), that the information and data are suitable for any particular purpose
• accept no liability for any interference with or damage to your computer, software or data occurring in connection with or relating to our website or its use or any website linked to our website. 

Further terms

We assume no responsibility for the accuracy or timeliness of any information provided herein. The information contained herein is for informational purposes only and is not conveyancing and/or legal advice or a substitute for legal and/or conveyancing counsel. Online readers should not act upon this information without seeking professional help.

Sites listed as hypertext links herein are not under the control J&A. Accordingly, J&A can make no representation concerning the quality, safety or suitability of the content of these sites nor can the fact that J&A has included this link serve as an endorsement by J&A of any of these sites. J&A is providing this site, the information, the listings, and the links contained herein only as a convenience to you.

The representative matters and other experience included herein may not contain full or complete client or entity name references and may contain colloquial rather than client or entity-specific name references. Any representative matters and other experience included herein should not imply current or former client status. You should not rely on any information contained herein, in particular any reference to representative matters and other experience, in making any decision, taking any action or refraining from taking any action.

The content, original images, and their arrangement herein are protected and owned by J&A.

Definitions

We means Jamili & Associates, including its officers and employees.

You means the person visiting our website and/or our official social media pages.