Sproal Property Law & Conveyancing is committed to protecting the privacy of individuals and is bound by the Australian Privacy Principles set out in the Privacy Act 1988.
1. Purpose of policy
Sproal & Associates Pty Ltd (ACN 159 218 023) trading as Sproal Property Law & Conveyancing (ABN 51 159 218 023) (we, us, our) is committed to protecting your privacy, in accordance with applicable Australian privacy laws.
This Policy is designed to give you a greater understanding of how we collect, use, disclose and otherwise handle personal information, and the steps we take to protect it. It does not cover our client confidentiality obligations (which are set out in our terms of engagement) or our privacy obligations in respect of credit reporting.
1.1 What is personal information?
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.
We are also required to comply with more specific privacy legislation in some circumstances, such as:
We are generally exempt from the Privacy Act when we collect and handle employee records, and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.
2. What personal information do we collect?
The type of personal information that we collect about you depends on the type of dealings you have with us. We may collect your personal information where you:
2.1 Sensitive information
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection. It includes health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record and some types of biometric information.
We only collect sensitive information where it is reasonably necessary for our functions or activities and either:
For example, we may collect health information or other sensitive information in the course of providing our services and we may collect information about your professional memberships for client relationship purposes.
2.2 Anti-Money Laundering and Counter-Terrorism Financing Compliance
We may be required to collect and use your personal information to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
These obligations require that we collect and verify information regarding you, your organisation and individuals associated with your organisation, or acting on behalf of yourself or your organisation. We may collect this information as part of our client onboarding processes as well as throughout our ongoing relationship with you.
If we are unable to collect and verify such personal information, then we may not be able to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and therefore we may not be able to provide our services to you or your organisation.
In order for us to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, we may collect personal information including:
We may collect this information from you or your organisation, and from third party service providers (InfoTrack or Perfect Portal and where applicable, their sub-processors) who assist us with conducting identity checks, background screening, verification checks and other due diligence processes.
Sproal Property Law & Conveyancing AML Collection Notice
2.3 Collection of information other than personal information through our website
When you visit our website, or one of our client portals, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
2.4 Site visit information
For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
2.5 Cookies
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users although they do identify the user’s internet browser.
We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website, for example to allow the website to remember who you are by keeping server variables linked to your session.
We only use non-persistent cookies. That is, they are held on your browser’s memory only for the duration of your session.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
What if you don't provide us with your personal information?
The nature of the business carried on by Sproal Property Law & Conveyancing means that, generally, it is not possible for us to provide services to our clients anonymously. However, in some circumstances, we allow individuals the option of not identifying themselves, or of using a pseudonym, when dealing with us (for example, you can view our website and make general phone queries anonymously).
3. How we collect personal information
In the course of providing legal services, we collect personal information in a number of ways, including:
4. Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are to:
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are:
We may use your personal information to send you information about our products and services, including legal updates and relevant products and services of third parties either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone or social media campaigns.
Where you have consented to receiving these communications from us, that consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
5. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out under heading 4, including:
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
We will ensure that any third party service provider that we share your information with commits to an appropriate level of security and confidentiality to protect your personal information.
6. Cross border disclosure of personal information
We may disclose personal information to third parties located overseas in the following situations:
In each case, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information and ensure that contractual arrangements and any other appropriate safeguards are in place to ensure that your personal information is protected.
7. What happens if we cannot collect your personal information?
If you do not provide us with your personal information, we may not be able to verify your identity and provide you (or the person you are acting on behalf of) with the legal services you have requested.
8. Data quality and security
We hold personal information in a number of ways, including in hard copy documents, electronic databases, email contact lists, and in paper files held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:
You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.
The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our premises, policies on document storage and security, personnel security, staff training and workplace policies.
8.1 Online credit card payment security
We process payments using online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected. If we receive instructions to make payments to your bank account, we may disclose your personal information to the extent necessary to ensure that bank account or identity information provided to us is correct.
8.2 Website security
While we strive to protect the personal information and privacy of users of our websites, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 11 below).
8.3 Third party websites
Links to third party websites that are not operated or controlled by us are provided for your convenience. We are not responsible for the privacy or security practices of those websites, which are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.
9. Access and Correction
Please contact our Privacy Officer (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions that are permitted by law.
We will also generally provide access in the manner that you have requested (e.g. by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
Except in the case of more complicated requests or any exceptions, we will endeavour to respond to access and correction requests within 30 days.
10. Complaints
If you have a complaint about how we have collected or handled your personal information, please contact our Privacy Officer (details under heading 11 below), who will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.
If your complaint can’t be resolved at the first instance, we will ask you to submit a Privacy Complaint , explaining the circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how you believe your complaint should be resolved.
10.1 Complaints Process
We will endeavour to acknowledge receipt of the Privacy Complaint within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner. This may include, for example, gathering the relevant facts, locating and reviewing relevant documents and speaking to relevant individuals.
In most cases, we expect that complaints will be investigated, and a response provided within 30 days of receipt of the Privacy Complaint. If the matter is more complex and our investigation may take longer, we will write and let you know.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information) or, in some instances, other regulatory bodies, such as the Australian Communications and Media Authority.
11. Our contact details
If you have any queries about the personal information that we hold about you or the way we handle that personal information, please contact our Privacy Officer, Jack Hickey, Business Manager.
Mail: Sproal Privacy Officer, PO Box 1024, Launceston TAS 7250
Email: info@sproal.au
Telephone: 03 6331 5500
Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au/ or by calling the OAIC’s enquiry line at 1300 363 992.
12. Changes to this Policy
This Privacy Policy was last updated in June 2026. We may amend this Privacy Policy from time to time. A current version will be posted here on our website and a copy may also obtained by contacting our Privacy Officer (details above).