Titan Partners is a privacy and legal compliance conscious organisation. This Privacy and AML/CTF Compliance Statement (Statement) demonstrates our commitment to your privacy. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) set out in the Privacy Act.

 

From time to time, Titan Partners is required to collect, hold, use and/or disclose personal information relating to individuals (including, but not limited to, its clients, contractors, suppliers and employees) and Titan Partners data and information in the performance of its business activities.

 

"Personal information" means any information or opinion about an individual whose identity is

apparent, or can reasonably be ascertained, from the information or opinion and:

 

• which may be true or untrue;

• which may be recorded in a material form or otherwise; and

• which is received, created, held, or otherwise handled during the course of, or in

connection with, an individual's engagement with us.

 

“Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinion, membership of political association, religious beliefs or affiliations, philosophical beliefs, member membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health or biometric information.

 

Employee Records Exemption

 

This Statement does not apply to the collection, holding, use or disclosure of personal information that is an employee record.

 

An employee record is a record of personal information relating to the employment of an employee. The exemption for the purposes of section 7(1)(ee) of the Privacy Act applies if an organisation acts, or a practice engages in affairs that directly relate to:

 

• either a current or former employment relationship between the employer and the individual; and

• an employee record held by the organisation and relating to the individual.

 

Please see the Privacy Act for examples of employee records.

 

Collection, Use and Disclosure of Personal and/or Sensitive Information

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Titan Partners only collects, holds, uses and/or discloses information that is reasonably necessary for one or more of its business functions or activities by lawful and fair means.  These activities are subject to any legal obligations by which we are bound (e.g. confidentiality, contractual and professional obligations).  Titan Partners may collect, hold, use and/or disclose your personal information in accordance with this Statement and circumstances where you would reasonably expect us to collect, hold, use and/or disclose your information.

 

Titan Partners may also collect, hold, use and/or disclose information if consent is obtained, or if required or authorised under law.  There may also be circumstances where we ae required by law to collect, hold, use and disclose personal information (e.g. to comply with legally enforceable information disclosure requirements and to comply with legal obligations to identify our clients).

 

The information Titan Partners collects about you depends on the nature of your dealings with the company and what you choose to share with us. The information we collect may include:

 

• Name

• Mailing or residential address

• Date of birth

• Email address

• Phone number

• Bank account details

• Next of kin/ emergency contacts

 

In some circumstances, Titan Partners may need to collect sensitive information about you. If we collect sensitive information we will do so with your consent, and only if it is necessary and relevant to your engagement with us.

 

Titan Partners may use or disclose your personal information for the purpose of providing you with our services, informing you about our services, upcoming promotions and events, or other opportunities that may interest you. For example, we may disclose your personal information to:

 

• third party services providers such as IT, HR or payroll providers

• marketing provides

• other professional services advisors

 

If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us directly.  If you opt-out of receiving marketing material from us, Titan Partners may still contact you in relation to its ongoing relationship with you.

 

You can always decline to give Titan Partners any personal information we request, but that may mean we cannot provide you with some or all the services you have requested. 

 

Titan Partners will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Titan Partners to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

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Security of Information

 

Titan Partners will take all reasonable steps to protect the personal and/or sensitive information it holds from misuse, interference, loss and from unauthorised access, modification, or disclosure.

 

Reasonable steps will depend on the circumstances, and are relevant to the nature of our business, however these may include both technical and organisational measures such as implementing two factor authentication processes, strong passwords, physical security measures, staff training and security procedures, as appropriate.

 

Where Titan Partners no longer needs personal information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy the information or ensure that it is de-identified.

 

Titan Partners may allow your personal information to be shared or stored overseas.  We will do this where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services (e.g. a service provider who stores and processes our online data).  These services commonly involve diverse geographical locations which change from time to time for reasons which include data protection and processing efficiency.  Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in.

 

Where you are in a different country location than us or when our services necessarily involve overseas disclosures, we may share your personal information with those who are overseas. 

 

We will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

You are entitled to access your personal information held by Titan Partners on written request. To request access to your personal information or if you have any questions or concerns regarding privacy at Titan Partners, please contact our Privacy and AML/CTF Compliance Officer using the contact details below.

 

Privacy and AML/CTF Compliance Officer (Titan Partners)

Email: compliance@titanpartners.com.au

Telephone: +61 2 9268 3300

Address: Level 3, 7 Macquarie Place, Sydney NSW 2000

 

You will not be charged for making a request to access your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

 

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in any information we hold about you and letting us know if your personal details change. However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.  We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

 

Automated Decision-Making

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“Automated decision-making” means any technology that processes personal information and uses computation to make or execute a decision (without a human decision-maker) or substantially and directly assist human staff to make decisions, where the decision could reasonably be expected to significantly affect the rights or interests of an individual. Such technology may include but is not limited to artificial intelligence (AI), machine learning (ML) and/or data analytics.

 

At Titan Partners, these systems may be used in various areas both internally and externally.

 

This Statement ensures that the use of automated decision-making is transparent, fair, accountable, and respects the rights and privacy of all individuals involved, including our employees, contractors, clients, and third-party vendors associated with Titan Partners. Titan Partners is committed to aligning its automated decision-making systems with the APPs, focusing on the following key principles:

 

Transparency: Employees and stakeholders will be clearly informed when automated decision-making processes are in use. This includes a thorough explanation of the system’s purpose, the data involved, and what and/or how decisions based on the information are made.

 

Fairness: Automated decisions will be made impartially, avoiding any discrimination based on age, gender, race, ethnicity, religion, disability, or any other protected characteristic as outlined in Australia’s federal anti-discrimination laws.

 

Accuracy: The data used in decision-making will be accurate, current, and complete to the best of our knowledge and belief. Titan Partners will take reasonable steps to ensure that information collected is reliable, relevant, and strictly necessary for the company’s functions or activities.

 

Accountability: Automated decisions will be subject to human oversight and review. In the event of disputes or errors affecting you, you will have access to a process for addressing and correcting decisions made by automated systems.

 

Security and Data Protection: Titan Partners is committed to safeguarding the secure collection, processing, and storage of personal data. Regular reviews and security risk assessments of automated systems will ensure that reasonable steps are taken to protect information from misuse, interference, loss, or unauthorized access, modification, or disclosure.

 

Titan Partners will keep up-to-date with evolving laws and regulations surrounding automated decision-making and make adjustments to this Statement as needed.

 

Credit Reporting

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Our credit reporting policy (CRP) has been developed in accordance with the Privacy Act and the Credit Reporting Code (CRC).  The CRP details how we generally manage your credit-related information.

 

The type of credit-related information that we collect from you may include:

• your identity information

• your repayment history

• any arrangement that you enter into with a credit provider

• court proceedings information, personal insolvency information and credit-related publicly available information

• administrative information relating to credit (e.g. account numbers)

 

We will only collect, use and/or disclose your credit information as reasonably necessary for our business purposes and as permitted by law, which include:

• to make business decisions

• to assist you to avoid defaulting on your credit-related obligations

• to undertake debt recovery and enforcement activities

• to deal with complaints and meet legal and regulatory requirements

 

We will give you prior notice of our intention to disclose your credit information to the credit reporting bureaus for the above-described purposes and where the Privacy Act permits us to do so.

 

If permitted by law and in some circumstances with your consent, we may disclose your credit information with third parties.

 

Please contact our Privacy and AML/CTF Compliance Officer if you believe that any credit information held by us about you is incorrect. We will attempt to resolve your correction request in a timely manner.  If we decline your request to correct credit information we hold about you we will notify you and state our reasons and the mechanisms available to you to complain about our decision.

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AML and CTF

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The Anti-money Laundering and Counter-terrorism Financing Act 2006 (Cth) (the AML/CTF Act), as reformed, is designed to stop illegal funds from entering the Australian financial system.  From 1 July 2026, Titan Partners will be required to verify our client identity, assess the risk of money laundering or terrorism financing and monitor client activity and report suspicious behaviour. 

 

Under this legislation, we may need to collect your identity documents (e.g. passport or driver's licence), proof of address, company records, trust deeds, or information on the source of funds.  We may also need to identify and verify any individual that controls a company, trust or other structure.  We will only collect what is required by law and for the regulatory purposes.  All data/information collected will be stored securely and handled in confidence.  If commercially viable, we may use accredited third-party providers to perform the AML/CTF checks, and we reserve the right to pass on third-party disbursement costs incurred as part of the client onboarding process.  If we do so, these costs will be itemised on your invoice.

 

You are recommended to stay informed of the AML/CTF Act and relevant legislation by visiting AUSTRAC website (www.austrac.gov.au).

 

If you have any questions concerning our AML/CTF checks or practices, please contact our Privacy and AML/CTF Compliance Officer.

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Disclosure

 

Titan Partners may disclose your personal information in accordance with this policy and

circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

 

• Third party services providers such as IT, HR or payroll providers

• Marketing provides

• Other professional services advisors

 

Breaches

 

A breach is defined as when information held by an organisation is accessed by someone else without authority. Any breaches of this Statement will be investigated and treated seriously.

 

Any breach or suspected breach of this Statement must be reported to Titan Partners' Privacy and AML/CTF Compliance Officer. If necessary, Titan Partners' Privacy and AML/CTF Compliance Officer will then report known or suspected breaches to the Office of the Australian Information Commissioner as required.

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Questions and complaints

 

If you have any questions or concerns regarding your privacy, or if you would like to make a complaint about a possible breach of this Statement or the Australian Privacy Principles, you may direct your correspondence to our Privacy and AML/CTF Compliance  Officer.

 

We take all complaints seriously and will respond to your complaint within a reasonable period.

 

If you believe that we have not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner whose contact details are as follows:

 

Office of the Australian Information Commissioner

GPO Box 5288

Sydney NSW 2001

t: 1300 363 992

Link to Privacy Complaint Form (https://webform.oaic.gov.au/prod?entitytype=Complaint&layoutcode=ComplaintWF ) 

 

Additional information

 

For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

 

We may modify or update this Statement from time to time. We will notify you of any modification or update via our website unless the law requires the change to be made otherwise.