MemberCheck Privacy Policy

Privacy Policy

MemberCheck is an Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) service designed for the superannuation industry and has been developed to assist superannuation trustees and their service providers to meet their obligations under the AML/CTF Act 2006, which came into effect on 12 December 2007.

MemberCheck is committed to protecting the privacy of individuals whose information is contained in our databases, and to assisting in resolving any issues that may arise in relation to this information.

The databases maintained by MemberCheck contain personal information about individuals. MemberCheck maintains strict security over this personal information. MemberCheck obtains personal information from a commercial supplier of AML/CTF watchlists, from customers regarding their members and from customers permitted to use the MemberCheck service. MemberCheck will only collect, use or disclose an individual’s personal information as permitted by the National Privacy Principles in the Privacy Act 1988 and will not use the information for any purpose other than to assist superannuation trustees and their service providers to meet their obligations under the AML/CTF Act.

Factiva Limited, a News Corporation company incorporated in the UK, provides information services, including a people database (the “Dow Jones Watchlist”) used by financial institutions for “know your customer” and other compliance purposes. Factiva has granted MemberCheck rights to the Dow Jones Watchlists for the purpose of assisting superannuation trustees and their service providers to meet their obligations under the AML/CTF Act. Factiva’s processing of the Dow Jones Watchlist, including the transfer of the Dow Jones Watchlist to MemberCheck, is carried out in accordance with the requirements and relevant provisions of the UK Data Protection Act.

Factiva has agreed to provide MemberCheck with all reasonable assistance requested by MemberCheck for the purpose of MemberCheck complying with its obligations under the Privacy Act 1988 and the National Privacy Principles.

National Privacy Principles (NPP)

Outlined below is an overview of how MemberCheck complies with the National Privacy Principles of the Privacy Act.

NPP 1 - Collection

MemberCheck collects personal information necessary for its AML/CTF service from third party data sources that are accessible in accordance with privacy and other laws. The nature of our business does not lend itself to direct collection from individuals themselves. MemberCheck also receives personal information from customers using the MemberCheck service.

MemberCheck seeks assurances from all its data sources that the information has been collected and is held in accordance with applicable privacy laws.

NPP 2 - Use & Disclosure

The information held by MemberCheck in the various databases is only used for the primary purpose of assisting customers with their AML/CTF obligations under relevant laws.

NPP 3 - Data Quality

MemberCheck takes a number of steps to ensure that the personal information we use or disclose is accurate, complete and up-to-date.

NPP 4 - Data Security

MemberCheck takes all reasonable steps to ensure that the personal information it holds is protected from misuse and loss and from unauthorised access, modification or disclosure.

MemberCheck also takes reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose for which it may be used or disclosed under NPP 2.

NPP 5 - Openness

MemberCheck’s Privacy Policy explains our policies on our management of personal information and is available on our website and on request. If requested by an individual, MemberCheck will take reasonable steps to advise that individual what sort of personal information is held, for what purposes, and how MemberCheck collects, holds, uses and discloses that information.

NPP 6 - Access & Correction

Where MemberCheck holds personal information about an individual, we will provide the individual with access to that information on request, except to the extent of the exceptions provided for in the Privacy Act. MemberCheck reserves the right to make a reasonable charge for providing access to the information, but there is no charge for making a request for access. Requests must be made in writing with sufficient identification provided to authenticate the individual.

If an individual establishes that their personal information is not accurate, complete or up-to-date, MemberCheck will take reasonable steps to correct the information. Corrections will need to be referred back to the source of the information.

NPP 7 - Identifiers

MemberCheck does not collect or hold any personal ‘identifiers’ assigned to individuals by Commonwealth agencies, such as Tax File Numbers or Medicare numbers.

NPP8 - Anonymity

It is not practicable for MemberCheck to offer individuals anonymity when transacting with MemberCheck.

NPP 9 - Transborder Data Flows

MemberCheck will not provide its service to any customers outside Australia unless that customer is subject to a law, binding scheme or contract which upholds the National Privacy Principles.

NPP 10 – Sensitive Information

MemberCheck does not collect any sensitive information as defined in the Privacy Act from its customers. Any collection of sensitive information from within the Factiva watchlists is permissible under NPP10.1(b) as it assists customers with their AML/CTF obligations under the relevant laws.


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MemberCheck will:

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MemberCheck will not share any personal information with third parties.