TABLE OF CONTENTS
INTRODUCTION .................................................................................................................. 3 THE PROJECT ..................................................................................................................... 3 CORE QUESTIONS.............................................................................................................. 3 PERSONAL INFORMATION ................................................................................................ 3 Authority .............................................................................................................................. 3
Modification of Existing Programs ...................................................................................................... 4
Who is to be consulted ....................................................................................................................... 4
THRESHOLD ASSESSMENT .............................................................................................. 4 FUTURE ACTIONS .............................................................................................................. 5
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INTRODUCTION
This is a Threshold Assessment undertaken for the Induction Refresh Project
proposed by the Organisational Development Team. It was undertaken by the
Organisational Development Team (lead contact: s 22(1)(a)(ii) ) and s 22(1)(a)(ii)
of the Privacy and Information Access Team.
THE PROJECT
Through the Fintel Al iance public private partnership, AUSTRAC is working with
government and industry partners to target the placement stage of money
laundering.
A dedicated project has been established to analyse cash deposits into Australian
bank accounts to identify indicators and target organised crime syndicates involved
in money laundering.
CORE QUESTIONS
• Does the project propose to collect personal information? Yes
• Does the project propose to store personal information? Yes
• Does the project propose to use personal information? Yes
• Does the project propose to disclose personal information? Yes
PERSONAL INFORMATION
The project wil collect the following information:
• Personal identification information of individuals conducting and receiving cash
deposits across the counter and through automatic teller machines. Personal
information wil include name, date of birth, address and bank account
information.
• There are no sensitive fields of personal information identified in the above
information.
Authority
• The primary purpose of the project is to support the functions of the AUSTRAC
CEO under section 212 of the AML/CTF Act 2006, specifically to support
domestic and international efforts to combat money laundering and terrorism
financing and other serious crimes.
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• Information wil be obtained from reporting entities under section 167 of the
AML/CTF Act 2006, with analysis of the information disseminated to law
enforcement under section 121 of the AML/CTF Act.
• There is no intention to undertake secondary use of the information.
• Information collected wil be stored securely on AUSTRAC systems and only
made available to project members holding an appropriate Australian
Government security clearance for the purpose of identifying money laundering
and other serious crimes.
• Information collected is proposed to be stored for a period of 12 months before
being deleted from AUSTRAC systems.
Modification of Existing Programs
• No modification proposed
Who is to be consulted
• During the course of the project, AUSTRAC wil engage with major financial
institutions and law enforcement as the primary stakeholders.
• Financial institutions wil provide the data to AUSTRAC and receive insights
following the analysis of the data.
• Law enforcement partners at the Commonwealth and State level wil receive
referrals and insights following analysis of the data. It is expected law
enforcement wil investigate the referrals and undertake operational activity.
THRESHOLD ASSESSMENT
• This project is an extension of the Third party cash deposits project, a PIA of
which can be found here: Document Overview: Third Party Cash Deposits - PRIVACY
IMPACT ASSESSMENT.docx - AUSTRAC - s 22(1)(a)(ii)
• That project was held to be low risk.
• I note that the collection of personal information in this extension of the project is
slightly different, being, as I understand it, collection relating to cash transactions
between $2000-$9,999. This is below the TTR limit expressly set out in s 43 of the
AML/CTF Act.
• The risk factor relating to this project is that the increased number of individuals
affected. A breach
• This risk is mitigated by the following factors:
o the fact that the information being collected is limited in scope, being limited
to the terms of a s 167 notice. This does not appear to be an ongoing
collection of information;
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o the information to be collected is within the bounds of the previous PIA;
o The use of a s 167 notice is an established collection activity, and the
collection is governed by a established processes;
o the information to be collected is authorised by the AML/CTF Act, being a
collection under s 167 of the AML/CTF Act.
o There are proposed limits to the use of the information and the length of time
the information will be kept by AUSTRAC.
• On the basis of the above, This collection does not raise serious privacy concerns, so
long as it continues within the established communicated boundaries. No PIA is
required for this project.
FUTURE ACTIONS
•
PIAT officer to set out any future actions to be undertaken which run counter to
the information provided in relation to this collection.
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