This document explains how Pearler (ABN 32 625 120 649) (Pearler, we, us, our) will collect, use, disclose and store your personal information to verify your identity documents using the Attorney-General’s Department’s Document Verification Service (DVS). This will only occur with your express consent.

We are bound by the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), as well as the Identity Verification Services Act 2023 (Cth) (IVS Act). Your personal information will be handled in accordance with our obligations under those Acts.

If you have any specific needs or require this notice in an alternative format, or if you need assistance due to any special circumstances, please contact us using the details at the end of this notice.

We collect your personal information for the purpose of verifying your identity. We are required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to verify your identity before we can open your account and provide you with our products and services.

We do not use the personal information collected to verify your identity for marketing, market research, profiling, audience matching or segmentation, and we do not disclose it to others for those purposes.

We collect your personal information through our website and our mobile application.

The information you provide will be sent through the DVS Hub, operated by the Attorney-General’s Department, and matched against official records held by the government agency responsible for issuing the identity document (document issuer).

The DVS Hub will advise us of whether the information you provide matches official records.

We do not store copies of your identity documents. We keep only the result of the check. We are required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to keep that result for seven years after the end of our relationship with you. Copies of your identity documents are held by FrankieOne, our gateway service provider, which keeps them for anti-money laundering purposes. FrankieOne retains them indefinitely unless we ask for them to be deleted. If you ask us to delete your records, we will make a determination based on any products or services we provide, or have provided you in the past, such that we are conforming to relevant legislation and requirements of our partners.

The DVS Hub facilitates information transfer between us and the document issuer. The DVS Hub itself does not retain any personal information and the Attorney-General’s Department cannot view or edit any of the personal information transmitted through the DVS Hub.

The Attorney-General’s Department engages a third-party provider as a managed service provider for the DVS, who is required to adhere to the APP requirements and security standards to ensure the use and disclosure of personal information is limited to explicitly defined purposes including: (a) for the purposes of the contract with the department; and (b) to comply with any request under section 95C of the Privacy Act.

The Attorney-General’s Department is authorised to operate the DVS Hub for the purpose of verifying individual’s identities under the IVS Act.

For more information on how the Attorney-General’s Department may handle your personal information, see the Attorney-General’s Department’s Identity Verification Services Privacy Statement at https://www.idmatch.gov.au/resources/identity-verification-services-privacy-statement

Your personal information will be shared by the Attorney-General’s Department via the DVS Hub with the government agency that issued your identity document to verify it against their official records. These agencies already hold your personal information as part of their official records, in line with their own privacy policies and legal obligations.

You do not have to agree to verify your identity documents through the DVS. We ask for your consent each time we want to check a document electronically, and you can decline. If you decline, we will verify your identity manually and we will not send your details to the DVS. To arrange that, contact our customer support team using the details at the end of this notice. Manual verification requires 100 points of identification under the Australian Federal Police 100 point checklist. At least one of those documents must be a primary document, and you must give us a copy of it certified by an authorised person, such as a Justice of the Peace. Manual verification takes longer, and the documents we ask for are more stringent.

We also verify identity manually in other situations, for example where an electronic check does not return a match, or where you pass that check but we need more information for another reason. In those cases we may ask to check the documents you give us through the DVS as well. We will ask for your consent before we do, and you can decline.

However, if you do not provide the personal information we require to verify your identity, we may not be able to provide you with certain products, services or offerings. If we cannot verify your identity, we cannot open the account you have asked for.

Where necessary, we may disclose your personal information to third parties, including the following categories of intermediary service providers involved in the use of the DVS who may receive your identification information to make or receive an information match request:

We may also disclose your personal information to law enforcement agencies in certain circumstances.

There may be circumstances in which we will require assistance to verify your identity. If we request assistance from the Attorney-General’s Department to verify your identity through the DVS, the Attorney-General’s Department will collect your personal information for the purposes of verifying your identity documents through the DVS.

The Attorney-General’s Department may also disclose your personal information to the relevant document issuer to assist them with verifying your identity documents. This collection is authorised under APP 5.2(c) and section 27 of the IVS Act which permits the collection of your personal information from someone other than yourself when it is authorised under an Australian law.

The Attorney-General’s Department will handle your personal information in accordance with their obligations under the Privacy Act.

Where the identity documents you require to be verified include information regarding other individuals (such as a Medicare card covering multiple individuals), it will be assumed that you have advised those individuals and obtained their consent to the disclosure. This information will only be used for the purposes of verifying your identity documents through the DVS. Any personal information of other individuals will otherwise be managed in the same way as your personal information.

There may be overseas disclosure of your personal information to recipients located in New Zealand where New Zealand government agencies or private organisations request for verification assistance of your identity documents.

If you don’t provide your personal information to the Attorney-General’s Department, the Department will be unable to verify your identity documents.

More information about the verification assistance service is set out in the Attorney-General’s Department’s Identity Verification Services Privacy Statement.

More information about how we handle your personal information is set out in our Privacy Policy at https://pearler.com/legal/privacy. Our Privacy Policy outlines how you can access and seek correction of the personal information that we hold about you. It also contains information about our complaint handling process, including how you may complain about a breach of the Australian Privacy Principles or a registered APP code, and how we will deal with such a complaint.

Email: help@pearler.com

Telephone: (02) 5747 4747, Monday to Friday, 9am to 5pm

Postal address: Privacy Officer, Pearler, Level 2, Suite 204, 98 Riley Street, Darlinghurst NSW 2010