Privacy policy

1. Who we are

This policy applies to Veritrace (“Veritrace”, “we”, “us” or “our”), an open-source intelligence and investigations practice operating across Australia.

• ABN: 47 391 284 457
• Investigator licence No.: 530999150
• Email: enquiries@veritrace.com.au

We are committed to protecting personal information and to handling it lawfully, fairly and transparently. This policy explains what we collect, why, and the choices and rights you have.

2. What this policy covers

Because of the nature of our work, we handle personal information in two distinct capacities:

Clients and enquirers

Information about the people who contact us, engage us, or represent an organisation that does. In respect of this information we generally act as the entity that decides how it is handled.

Subjects of investigations

Information about individuals who are the subject of an engagement, collected from lawfully accessible open sources on the instructions of a client with a legitimate purpose and lawful basis. In respect of this information we ordinarily collect and analyse it for, and disclose it to, the instructing client.

3. The personal information we collect

From clients and enquirers, we may collect:

• Name, organisation, role and business contact details;
• The details of your enquiry, instructions and correspondence with us;
• Billing and payment-related information; and
• Records of the lawful basis and legitimate purpose stated for an engagement.

In the course of an engagement, and only as scoped and instructed, we may collect personal information about a subject from open and lawfully accessible sources. This can include identity and contact details, addresses, employment and business associations, corporate and directorship records, court and regulatory records, publicly posted online activity, and other information relevant to the intelligence requirement. Some of this may be sensitive information; where it is, we collect it only where permitted by law and where it is reasonably necessary for the engagement.

4. How we collect it

We collect information directly from you when you contact us, submit the enquiry form, correspond with us, or engage our services. In the course of an engagement we collect information about subjects from lawfully accessible open sources, including public registers, court and tribunal records, corporate filings, publicly available online material and other open-source datasets, and from information you provide to us as the instructing client.

Our collection methods are passive. We do not use pretexting, impersonation, circumvention of access controls, or any unlawful means, and we do not purchase unlawfully obtained data.

5. Why we collect and how we use it

We use personal information to:

• Respond to enquiries, scope engagements and provide quotes;
• Carry out engagements and prepare the resulting reports and deliverables;
• Verify the lawful basis and legitimate purpose of an engagement;
• Manage our client relationships, billing and records; and
• Meet our legal, regulatory and professional obligations.

We collect only what the stated purpose reasonably requires, and we do not use personal information for unrelated purposes without your consent or another lawful basis.

6. Disclosure

We may disclose personal information to:

• The instructing client for whom an engagement is carried out;
• Service providers who support our operations (such as secure IT and communications providers) under confidentiality obligations;
• Professional advisers, and courts, tribunals or regulators where required or authorised by law; and
• Others where you have consented or where disclosure is otherwise permitted or required by law.

We do not sell personal information, and we do not disclose client engagements as marketing material without written consent.

7. Data quality

We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, up to date and complete for the purpose for which it is used. Our reports distinguish observed fact from inference, and material findings are corroborated and marked confirmed or unverified rather than presented as certainties.

8. Security and storage

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, using appropriate technical and organisational measures. Client engagement data is stored in Australia. Access is limited to those who need it to perform an engagement.

9. Retention

Retention periods are defined at the outset of an engagement and enforced. We keep personal information only for as long as is necessary for the purpose for which it was collected, or as required to meet legal, regulatory or professional obligations, after which it is securely destroyed or de-identified.

10. Access and correction

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date or incomplete, by contacting us at the details below. We will respond within a reasonable period. In some circumstances we may be permitted or required by law to decline a request — for example where the information relates to a subject of an engagement carried out for another party, or where access would prejudice a matter — and if so we will explain why and how you may respond.

11. Overseas disclosure

We primarily store and handle personal information in Australia. Some matters involve offshore elements, such as foreign corporate registers or international screening, and certain service providers may store data outside Australia. Where personal information is disclosed overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles.

12. Direct marketing

We do not send unsolicited marketing. Any operational communications about your enquiry or engagement relate directly to the service you have requested, and you may ask us to stop non-essential communications at any time.

13. Cookies and website analytics

This website can be browsed without providing personal information. If we use cookies or analytics to understand how the site is used, any information collected is used only to maintain and improve the site. You can control cookies through your browser settings.

14. Complaints

If you believe we have breached the Australian Privacy Principles or mishandled your personal information, please contact us first at enquiries@veritrace.com.au so we can investigate and respond. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

15. Changes to this policy

We may update this policy from time to time. The current version is always available on this page, with the “last updated” date shown at the top.

16. Contact us

For any privacy question or request, contact Veritrace at enquiries@veritrace.com.au.