Customer identification and verification

Smarter SMSF  |  Version 1.0  |  Effective: 1 September 2026

Who this notice is for. This notice is for individuals whose identity we are required to verify. If you are an adviser or firm engaging us on a client’s behalf, please provide this notice to your client before their verification begins.

Why we are asking for this

Smarter SMSF is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). The law requires us to identify and verify the people we provide certain services to, before we provide them.

This applies to SMSF establishments, limited recourse borrowing arrangement bare trusts, discretionary and unit trusts, company incorporations, and changes of trustee.

We cannot provide the service until this is complete. This is a legal requirement, not a policy of ours, and there are no exceptions available to us.

What we collect

  • Your full name, date of birth and residential address.
  • Details from your identification document — the type of document, who issued it, its number and expiry date.
  • Where verification is done electronically: an image of your identification document, and a photograph or short video of your face, used to confirm that the photo on your document is you.
  • Whether you are a politically exposed person, and the results of sanctions and adverse media screening.
  • For some customers, information about your source of funds or source of wealth.
  • If you are a director, shareholder, member, trustee or beneficial owner connected with a company, trust or fund, we may collect this information about you even though you are not the person who placed the order.

We never receive or store copies of your identification documents. They are held securely by our identity verification provider. What we receive is confirmation that your identity was verified, along with the risk assessment outcome. We record the details we are required to record, not the documents themselves.

Some of this is sensitive information

Your facial image and the biometric comparison are sensitive information under the Privacy Act 1988 (Cth).

We will ask for your express consent before any biometric check is carried out, and before any check is made against the Australian Government’s Identity Verification Services. You can decline — see “If you cannot complete the check” below.

Who we share it with

  • VerifiMe, our identity verification provider, which carries out the check.
  • The accounting, advice or legal firm that ordered the service on your behalf.
  • AUSTRAC, where the law requires us to report.
  • Law enforcement, regulators and government agencies, where required or authorised by law.

Your identity information stays in Australia. Our identity verification provider, the system we store verification records in, and the infrastructure our platform runs on are all located in Australia.

We do not sell, trade or rent your information, and we do not use it for marketing.

How long we keep it

Seven years after we stop providing services to you. This period is set by law. We are not able to delete these records earlier, even if you ask us to or close your account.

Your identity wallet

Once verified, you have an identity wallet with our verification provider. You grant us permission to see your identity status, and you can view or revoke that permission at any time. You can also reuse your verified identity with other organisations that use the same service, instead of starting again.

Revoking permission stops our future access. It does not remove the records we have already made — those we must keep for seven years, as above.

Something we may not be able to explain

The law makes it an offence for us to tell you if we have formed a suspicion about a matter, or reported one to AUSTRAC. If there is ever a point where we cannot explain why we have asked for more information, or why something has been delayed or declined, this is the reason.

If you cannot complete the check

The electronic check is the only method we offer directly. If you are unable to complete it, or you would prefer not to have a biometric check carried out, contact us or speak to the firm that engaged us — your identity may be able to be verified another way, including by that firm under a reliance arrangement.

If your identity cannot be verified, we are unable to provide the service and the order will not proceed.

Your rights

You can ask for access to the information we hold about you, and ask us to correct it if it is wrong. In limited cases we may be unable to give access — including where the law prevents us from doing so, as described above.

If you have a concern about how we have handled your information, contact our Privacy Officer, Aaron Dunn, at [privacy@smartersmsf.com] or 1300 95 94 76. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or at www.oaic.gov.au.

This notice should be read together with our Privacy Policy, available at https://smartersmsf.com/privacy-policy/, which explains our handling of personal information in full.